Talos®-C (HA) Cervical Intervertebral Body Fusion Devices are intervertebral body devices intended for use in skeletally mature patients with Degenerative Disc Disease (DDD) of the cervical spine at one level from C2-T1. Cervical degenerative disc disease is defined as intractable radiculopathy and/or myelopathy with herniated disc and/or osteophyte formation on the posterior vertebral endplates producing symptomatic nerve root and/or spinal cord compression confirmed by history and radiographic studies. Talos®-C (HA) Cervical IBF Devices are intended to be used with autologous bone graft to facilitate fusion.

Non-operative treatment prior to treatment with Talos®-C (HA) Cervical Intervertebral Body Fusion Devices is six (6) weeks.

Talos®-C (HA) Cervical IBF Devices are to be implanted via an open anterior approach. Talos®-C (HA) Cervical IBF Devices are also to be used with supplemental fixation.

Device Description

The Talos® -C (HA) Cervical Intervertebral Body Devices (Talos®-C (HA) Cervical IBF Devices) are made of the polymer, hydroxyapatite impregnated polyetheretherketone (HA PEEK). The devices are open devices with ridged teeth on superior and inferior ends to resist implant pullout. The Talos®-C (HA) Cervical IBF Devices are rectangular devices and have curved lateral walls and rounded edges. The implants are available in a range of sizes as well as flat and lordotic angled implants to accommodate variations in patient's anatomy. In addition, tantalum markers at the opposite ends are offered which allows the Talos®-C (HA) Cervical IBF Device radiological confirmation for proper positioning.

AI/ML Overview

The provided document is a 510(k) summary for a medical device called Talos®-C (HA) Cervical Intervertebral Body Fusion Devices. This type of regulatory filing demonstrates substantial equivalence to a legally marketed predicate device, rather than proving the device meets specific acceptance criteria through a clinical study with detailed results for sensitivity, specificity, and other performance metrics typically associated with AI/software devices.

Therefore, the requested information elements related to AI device performance are not applicable and cannot be extracted from this document. This document focuses on the mechanical and material equivalence to a predicate device, as well as the indications for use.

Here's an analysis based on the information available:

1. A table of acceptance criteria and the reported device performance

The document does not explicitly state "acceptance criteria" in terms of performance metrics like sensitivity, specificity, or AUC as one would expect for an AI device. Instead, the acceptance criteria for this 510(k) submission are implied to be the successful demonstration of substantial equivalence to the predicate device, particularly in terms of mechanical function and properties.

The reported device performance is that the Talos®-C (HA) Cervical IBF Devices are equal in mechanical function and properties to the predicate device, thereby establishing equivalency in safety and effectiveness.

Acceptance Criteria (Implied for 510(k) Mechanical Equivalence)	Reported Device Performance
Exhibit similar mechanical function and properties to the predicate device.	The Talos®-C (HA) Cervical IBF Devices were found to be equal in mechanical function and properties to the predicate device (K122850: Meditech Advisors, LLC Talos®-C Cervical Intervertebral Body Fusion Devices).
Pass tests according to ASTM 2077 (static compression, compression shear, torsion, dynamic compression, dynamic compression shear, dynamic torsion) and ASTM 2267 (subsidence testing).	The device successfully underwent testing according to ASTM 2077 (static compression, compression shear and torsion tests, dynamic compression, compression shear and torsion tests) and ASTM 2267 (subsidence testing).
Maintain mechanical integrity after simulated aging.	Simulated aging was performed, and the device was subjected to additional dynamic compression and torsion tests in accordance with ASTM 2077, implying successful performance post-aging.

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This document describes non-clinical mechanical testing of physical devices (implants), not a study involving patient data. Therefore, the concept of "sample size for the test set" in the context of patient data, data provenance, retrospective/prospective study, or country of origin is not applicable. The "test set" here refers to the physical devices manufactured and tested. The document does not specify the number of individual implants tested in each mechanical test, but it refers to standard ASTM methods, which typically involve a specified number of samples for statistical validity.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This is not applicable. The ground truth for mechanical testing is established by the physical measurements and standards defined in the ASTM test methods, not by expert human interpretation of data like in medical imaging.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This is not applicable as it pertains to human interpretation of data, which is not what this document describes.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

This is not applicable. This submission is for mechanical spinal implants, not an AI device or software that assists human readers.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

This is not applicable. This is not an algorithm or AI device.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The "ground truth" for this device's performance is based on established engineering standards and physical measurements from mechanical testing (e.g., force, displacement, cycles to failure) as defined by ASTM 2077 and ASTM 2267.

8. The sample size for the training set

This is not applicable. The device is not an AI or machine learning model that requires a training set.

9. How the ground truth for the training set was established

This is not applicable. The device is not an AI or machine learning model.

Summary

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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 consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the edge. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

February 22, 2015

Meditech Spine, LLC Mr. Jason Gromek Director of Engineering 1447 Peachtree Street, Northeast, Suite 440 Atlanta, Georgia 30309

Re: K142345

Trade/Device Name: Talos -C (HA) Cervical Intervertebral Body Fusion Devices Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: ODP Dated: January 20, 2015 Received: January 22, 2015

Dear Mr. Gromek:

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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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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meditech spir

1447 Peachtree St NE Suite 440, Atlanta GA 30309 | p (678) 974-5287 | f (404) 759-2104 | support@meditechspine.com

Indications for Use Form

510(k) Number (if known): K142345

Device Name: Talos®-C (HA) Cervical Intervertebral Body Fusion Devices

Indications for Use:

Non-operative treatment prior to treatment with Talos®-C (HA) Cervical Intervertebral Body Fusion Devices is six (6) weeks.

Talos®-C (HA) Cervical IBF Devices are to be implanted via an open anterior approach. Talos®-C (HA) Cervical IBF Devices are also to be used with supplemental fixation.

Prescription Use

(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NECESSARY)

Concurrence of CDRH, Office of Device Evaluation (ODE)

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meditech spine, IIc

1447 Peachtree St NE Suite 440, Atlanta GA 30309 | p (678) 974-5287 | f (404) 759-2104 | support@meditechspine.com

510(k) Summary

As required by section 807.92(c)

Meditech Spine, LLC is requesting marketing clearance for the Talos®-C (HA) Cervical Intervertebral Body Fusion Devices. Summary prepared on the 18th of February, 2015.

	A. Sponsor/Manufacturer:	Meditech Spine, LLC
	Registration Number:	3009405289
		Jason Gromek, Director of Engineering
		1447 Peachtree St NE Suite 440
		Atlanta, GA 30309
		678-974-5287 Phone
		404-759-2104 Fax

B. Trade Name: Talos®-C (HA) Cervical Intervertebral Body Fusion Devices Common Name: Spinal Implant Classification Name: Intervertebral body fusion device (21 CFR 888.3080 Class II, Product Code ODP)
Predicate Device: K 122850: Meditech Advisors, LLC Talos®-C Cervical ﻥ Intervertebral Body Fusion Devices

D. Device Description:

ت Intended Use:

Non-operative treatment prior to treatment with Talos®-C (HA) Cervical Intervertebral Body Fusion Devices is six (6) weeks.

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meditech spine, IIc

1447 Peachtree St NE Suite 440, Atlanta GA 30309 | p (678) 974-5287 | f (404) 759-2104 | support@meditechspine.com

Talos®-C (HA) Cervical IBF Devices are to be implanted via an open anterior approach. Talos® -C (HA) Cervical IBF Devices are also to be used with supplemental fixation.

F. Technological Characteristics:
The technological characteristics of the Talos®C (HA) Cervical IBF Devices are the same as the predicate device, except for the material. The new material is hydroxyapatite filled polyetheretherketone (HA PEEK). HA is a naturally occurring mineral in bone and is widely used in the orthopedic field.
G. Non-clinical Testing:
Tests according to ASTM 2077 and ASTM 2267 were performed on the Talos®-C (HA) Cervical IBF Devices to establish equivalency to the predicate device. The tests include static compression, compression shear and torsion tests, dynamic compression, compression shear and torsion tests, as well as subsidence testing. Simulated aging was performed on Talos®-C (HA) IBF Devices, which then were subjected to additional dynamic compression and torsion tests in accordance with ASTM 2077. The Talos®-C (HA) is equal in mechanical function and properties to the predicate device, establishing equivalency in safety and effectiveness.
H. Conclusion:
The testing completed as well as a comparison of the technological characteristics have demonstrated that the Talos®-C (HA) Cervical IBF Devices are substantially equivalent to the predicate device.

Regulation Number and Section

§ 888.3080 Intervertebral body fusion device.

(a)
Identification. An intervertebral body fusion device is an implanted single or multiple component spinal device made from a variety of materials, including titanium and polymers. The device is inserted into the intervertebral body space of the cervical or lumbosacral spine, and is intended for intervertebral body fusion.(b)
Classification. (1) Class II (special controls) for intervertebral body fusion devices that contain bone grafting material. The special control is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intervertebral Body Fusion Device.” See § 888.1(e) for the availability of this guidance document.(2) Class III (premarket approval) for intervertebral body fusion devices that include any therapeutic biologic (e.g., bone morphogenic protein). Intervertebral body fusion devices that contain any therapeutic biologic require premarket approval.
(c)
Date premarket approval application (PMA) or notice of product development protocol (PDP) is required. Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.