K Number
K142117
Device Name
INVISION TOTAL ANKLE REVISION SYSTEM
Date Cleared
2015-03-25

(233 days)

Product Code
Regulation Number
888.3110
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The INVISION™ Total Ankle Revision System is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis. The INVISION™ Total Ankle Revision System is additionally indicated for patients with a failed previous ankle surgery. CAUTION: The ankle prosthesis is intended for cement use only.
Device Description
The subject INVISION™ Total Ankle Revision System is a fixed-bearing system that is specifically designed considering revision procedures. Based on the INBONE® Total Ankle System platform, INVISION™ Total Ankle Revision System includes tibial trays that are compatible with the INBONE® Total Ankle System talar stems and INBONE® Sulcus Poly Inserts. To accommodate various patients' boney defects, the INVISION™ tibial trays are available in two heights: +4 mm and +8 mm, which are an additional 4 mm or 8 mm above the current INBONE® height.
More Information

Not Found

No
The summary describes a mechanical implant system for ankle revision surgery and does not mention any software, algorithms, or AI/ML capabilities.

Yes
The device is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis, and for patients with a failed previous ankle surgery, which clearly defines its role in treating or rehabilitating a medical condition.

No

The device description clearly states it is a "fixed-bearing system that is specifically designed considering revision procedures" and involves "tibial trays," indicating it is an implantable medical device for treatment, not diagnosis. The "Intended Use / Indications for Use" also describes conditions for which the device is used as a treatment ("damaged by severe rheumatoid, posttraumatic, or degenerative arthritis," or "failed previous ankle surgery").

No

The device description clearly states it is a "fixed-bearing system" and includes "tibial trays," which are physical components, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Description and Intended Use: The INVISION™ Total Ankle Revision System is a surgical implant designed to replace or revise a damaged ankle joint. It is a physical device implanted into the body, not a test performed on a sample outside the body.

The provided information clearly describes a medical device used in surgery, not an in vitro diagnostic test.

N/A

Intended Use / Indications for Use

The INVISION Total Ankle Revision System is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis.

The INVISION Total Ankle Revision System is additionally indicated for patients with a failed previous ankle surgery.

CAUTION: The ankle prosthesis is intended for cement use only.

Product codes

HSN

Device Description

The subject INVISION™ Total Ankle Revision System is a fixed-bearing system that is specifically designed considering revision procedures. Based on the INBONE® Total Ankle System platform, INVISION™ Total Ankle Revision System includes tibial trays that are compatible with the INBONE® Total Ankle System talar stems and INBONE® Sulcus Poly Inserts. To accommodate various patients' boney defects, the INVISION™ tibial trays are available in two heights: +4 mm and +8 mm, which are an additional 4 mm or 8 mm above the current INBONE® height.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

ankle joint

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)

K140749 INFINITY® Total Ankle System, K123954 INFINITY® Total Ankle System, K133585 INBONE® II Total Ankle System, K100886 INBONE® II Total Ankle System

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3110 Ankle joint metal/polymer semi-constrained cemented prosthesis.

(a)
Identification. An ankle joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace an ankle joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces and has no linkage across-the-joint. This generic type of device includes prostheses that have a talar resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a tibial resurfacing component made of ultra-high molecular weight polyethylene and is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized image of three human profiles facing right, stacked on top of each other. The profiles are black against a white background. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the image.

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

March 25, 2015

Wright Medical Technology, Incorporated Ms.Val Mvles Regulatory Affairs Specialist 1023 Cherry Road Memphis, Tennessee 38117

Re: K142117

Trade/Device Name: INVISION™ Total Ankle Revision System Regulation Number: 21 CFR 888.3110 Regulation Name: Ankle joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: HSN Dated: February 23, 2015 Received: February 24, 2015

Dear Ms. Myles:

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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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Page 2 - Ms. Val Myles

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 vours.

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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Indications for Use

510(k) Number (if known)

K142117

Device Name

INVISION Total Ankle Revision System

Indications for Use (Describe)

The INVISION Total Ankle Revision System is indicated for patients with ankle joints damaged by severe rheumatoid, posttraumatic, or degenerative arthritis.

The INVISION Total Ankle Revision System is additionally indicated for patients with a failed previous ankle surgery.

CAUTION: The ankle prosthesis is intended for cement use only.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

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This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Headquarters Wright Medical Technology, Inc.

1023 Cherry Road Memphis, TN 38117

901 867 9971 wmt.com

Image /page/4/Picture/3 description: The image contains the Wright logo. The logo consists of two overlapping trapezoids, one red and one orange, to the left of the word "WRIGHT" in red, and the words "FOCUSED EXCELLENCE" in gray below the word "WRIGHT". The logo is simple and modern, and the colors are bright and eye-catching.

510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

In accordance with the Food and Drug Administration Rule to implement provisions of the Safe Medical Devices Act of 1990 and in conformance with 21 CFR 807.92, this information serves as a Summary of Safety and Effectiveness for the INVISION™ Total Ankle Revision System.

| 1. | Submitted By: | Wright Medical Technology, Inc.
1023 Cherry Road
Memphis, TN 38117 |
|----|--------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Date: | February 23, 2015 |
| | Contact Person: | Val Myles
Regulatory Affairs Specialist
Office (901) 290-5162
Fax (901) 867-4190 |
| 2. | Proprietary Name: | INVISION™ Total Ankle Revision System |
| | Common Name: | Ankle Prosthesis |
| | Classification Name and Reference: 21 CFR 888.3110- Class II | |
| | Device Product Code, Device Panel: HSN - Orthopedic | |
| 3. | Predicate Device: | K140749 INFINITY® Total Ankle System
K123954 INFINITY® Total Ankle System
K133585 INBONE® II Total Ankle System
K100886 INBONE® II Total Ankle System |
| 4. | Device Description | The subject INVISION™ Total Ankle Revision System is a fixed-bearing system that
is specifically designed considering revision procedures. Based on the INBONE®
Total Ankle System platform, INVISION™ Total Ankle Revision System includes
tibial trays that are compatible with the INBONE® Total Ankle System talar stems |

and INBONE® Sulcus Poly Inserts. To accommodate various patients' boney defects, the INVISION™ tibial trays are available in two heights: +4 mm and +8 mm, which are an additional 4 mm or 8 mm above the current INBONE® height.

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5. Intended Use and Indications for Use

The INVISIONTM Total Ankle Revision System is intended to give a patient limited mobility by reducing pain, restoring alignment and replacing the flexion and extension movement in the ankle joint.

The INVISION™ Total Ankle Revision System is indicated for patients with ankle joints damaged by severe rheumatoid, post-traumatic, or degenerative arthritis.

The INVISIONTM Total Ankle Revision System is additionally indicated for patients with a failed previous ankle surgery.

CAUTION: The ankle prosthesis is intended for cement use only.

6. Technological Characteristics Comparison

The INVISION Total Ankle Revision System has identical indications, utilizes similar instrumentation, is made identical materials, and has identical sterilization methods when compared with the legally marketed predicate devices.

Substantial Equivalence- Non-Clinical Evidence 7.

Dimensional comparisons were used to demonstrated that the tibial trays of the INVISION™ Total Ankle Revision System does not present a new worst-case compared to the tibial trays of the INBONE® Total Ankle System.

8. Substantial Equivalence- Clinical Evidence

N/A

9. Substantial Equivalence- Conclusions

The design characteristics of the subject devices do not raise any new types of questions of safety or effectiveness. From the evidence submitted in this 510(k), the subject devices can be expected to perform at least as well as the predicate systems and are substantially equivalent.