K Number
K141937
Device Name
TRIDENT FUSION IMPLANT
Date Cleared
2014-09-10

(55 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Trident Fusion Implant has the following Indications for Use: Fixation of osteotomies and reconstruction of the lesser toes and lesser fingers following correction procedures for hammertoe, claw toe, mallet toe, and other deformities of the feet and hands.
Device Description
The Vilex Trident Fusion Implant is a single-piece cannulated bone screw intended for the fixation of PIP joints in lesser toes and digits. The device is offered straight or with a 10° bend at the joint. It is available in either stainless steel or titanium.
More Information

No
The device description and intended use clearly describe a mechanical bone screw for fixation, with no mention of AI or ML capabilities. The "Mentions AI, DNN, or ML" and "Mentions image processing" sections are explicitly marked as "Not Found".

Yes
The device is described as an implant used for fixation of osteotomies and reconstruction after correction procedures for deformities, which directly addresses a health condition or alters the structure/function of the body.

No
The device is described as a surgical implant for fixation of osteotomies and reconstruction of lesser toes and fingers, which indicates a therapeutic rather than a diagnostic function.

No

The device description clearly states it is a "single-piece cannulated bone screw" made of "stainless steel or titanium," indicating it is a physical hardware implant, not software.

Based on the provided information, the Trident Fusion Implant is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health. This includes tests for diagnosis, monitoring, or screening.
  • Trident Fusion Implant Function: The description clearly states the Trident Fusion Implant is a "single-piece cannulated bone screw intended for the fixation of PIP joints in lesser toes and digits." Its purpose is to physically stabilize bones after surgical procedures.
  • Lack of Specimen Analysis: There is no mention of the device analyzing any biological specimens from the patient.

Therefore, the Trident Fusion Implant is a surgical implant, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Trident Fusion Implant has the following Indications for Use: Fixation of osteotomies and reconstruction of the lesser toes and lesser fingers following correction procedures for hammertoe, claw toe, mallet toe, and other deformities of the feet and hands.

Product codes

HWC

Device Description

The Vilex Trident Fusion Implant is a single-piece cannulated bone screw intended for the fixation of PIP joints in lesser toes and digits. The device is offered straight or with a 10° bend at the joint. It is available in either stainless steel or titanium.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

lesser toes and lesser fingers

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Not Found

Key Metrics

Not Found

Predicate Device(s)

K111536, K120645, K101165

Reference Device(s)

K022599, K052736

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.

0

Image /page/0/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is an abstract image of three faces in profile, stacked on top of each other. The faces are stylized and appear to be connected.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

September 10, 2014

Vilex in Tennessee Inc. % Mr. Abraham Lavi, PhD Vilex. Inc. 8374 Market Street, Suite 167 Lakewood Ranch, Florida 34202

Re: K141937

Trade/Device Name: Trident™ Fusion Implant Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: HWC Dated: July 23, 2014 Received: July 25, 2014

Dear Dr. Lavi:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

1

Page 2 - Mr. Abraham Lavi, PhD

forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Lori A. Wiggins -S

for Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Image /page/2/Picture/1 description: The image shows the logo for Vilex Inc. The logo is red and features the word "VILEX" in a stylized font inside of a red box. Below the logo is the text "Manufacturer of Vilex™ bone implants, Power equipment & surgical instruments".

Phone: Fax: www.vilex.com (931) 474-7550 (931) 474-7551

111 Moffitt Street McMinnville, TN 37110 USA E-mail: info@vilex.com

INDICATIONS FOR USE

510(k) NUMBER: K141937

DEVICE NAME: Trident™ Fusion Implant

INDICATIONS FOR USE:

The Trident Fusion Implant has the following Indications for Use: Fixation of osteotomies and reconstruction of the lesser toes and lesser fingers following correction procedures for hammertoe, claw toe, mallet toe, and other deformities of the feet and hands.

Prescription Use × (Per 21 CFR 801.109)

Concurrence of CDRH, Office of Device Evaluation (DOE)

Page 1 of 1

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Image /page/3/Picture/0 description: The image shows the logo for Vilex Inc. The logo consists of the word "VILEX" in large, red, bold letters, with the letters connected to form a rectangular shape. Below the logo, the text reads "Manufacturer of Vilex™ bone implants, Power equipment & surgical instruments".

Phone:
Fax: www.vilex.com (931) 474-7550 (931) 474-7551

111 Moffitt Street
McMinnville, TN 37110 USA E-mail: info@vilex.com

510(k) Summary Trident Fusion Implant K141937

Sponsor:Vilex in Tennessee, Inc
Contact Person:Abraham Lavi
Date Prepared:September 4, 2014
Trade Name:Trident Fusion Implant
Common Name:Threaded metallic bone fixation fastener
Classification
Name:21 CFR 888.3040 - Smooth or threaded metallic bone fixation fastener
Product Code:HWC/ Orthopedics, Class II
Predicate Devices:K111536
K120645, K101165
DigiFuse, MetaSurg
Pro-Toe, Wright Medical
K022599
K Wire, Newdeal
K052736
K-Wire, Arthrex
Description of
Device:The Vilex Trident Fusion Implant is a single-piece cannulated bone screw intended for the
fixation of PIP joints in lesser toes and digits. The device is offered straight or with a 10° bend
at the joint. It is available in either stainless steel or titanium.
Indications for
Use:The Trident Fusion Implant has the following Indications for Use:
Fixation of osteotomies and reconstruction of the lesser toes and lesser fingers following
correction procedures for hammertoe, claw toe, mallet toe, and other deformities of the feet
and hands.
Technological
Characteristics:The technological characteristics for the Trident Fusion Implant are the same as the
characteristics of the predicate devices. All of the sizes included in the Vilex Trident Fusion
Implant system are within the range of offerings of the predicate devices and the designs of
the Trident devices are similar to the predicate devices. The materials used to manufacture
the Trident Fusion Implants are the same as those used to manufacture the predicate devices.
Substantial
EquivalenceThe design features of the Trident Fusion Implant are substantially equivalent to the design
features of other predicate devices previously cleared for market. The methods used to
establish equivalence are indications for use, material of construction, sizes, and shapes. The
safety and effectiveness of the Trident Fusion Implant are adequately supported by the
substantial equivalence information, material information and analysis data provided within
this Premarket Notification. Therefore, it is concluded that the Trident Fusion Implants are
substantially equivalent to the noted predicate devices.

4

510(k) Summary Triden Fusion Implant

Conclusions:While the Trident Fusion Implants are not identical to the predicate devices, any differences that may exist do not significantly affect device safety and effectiveness. In addition, the differences do not add new or increased risks and complications. Therefore, it is concluded that the Trident Fusion Implants are substantially equivalent to the predicate devices as outlined previously and should not render the subject device NSE.
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