The Opticage® Expandable Interbody Fusion Device is a posterior lumbar intervertebral body fusion device and is indicated for use with autogenous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The Opticage Interbody Fusion Device can be implanted via posterior, transforaminal or lateral approach.

DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Candidates for surgery should be skeletally mature and have had six months of conservative treatment. These patients may have had primary or secondary surgery, but no previous fusion at the involved levels.

The device is not intended to be used as a stand-alone device. It must be used with supplemental internal spinal fixation systems that have been cleared for use in the lumbar spine (i.e. facet screw fixation systems, facet compression devices and posterior pedicle screw and rod systems).

Device Description

The Opticage Expandable Interbody Fusion Devices are provided gamma sterilized and are for single use only. The devices are designed for lumbar intervertebral body fusion via posterior, transforaminal or lateral approach. They are fabricated from titanium alloy (Ti-6AI-4V) as per ASTM F136. Each device consists of five components: an upper and lower titanium plate, two titanium wedges and a central shaft. The faces of the upper and lower plates of the devices contain teeth and fenestrations to enhance bony in growth. The two titanium wedges are connected by the central shaft. The shaft can be rotated clockwise to move the wedges toward the center of the device thereby increasing the distance (i.e. height) between the upper and lower titanium plates. Alternatively, the shaft can be rotated counter clockwise to move the wedges away from the center of the device causing the distance (i.e. height) between the upper and lower plates to decrease. In this manner, the height of the construct can be continuously adjusted through a range of 5mm. A cavity internal to each device is intended to hold autogenous bone graft. The Opticage is available in a variety of configurations.

AI/ML Overview

This appears to be a 510(k) summary for the Opticage® Expandable Interbody Fusion Device. Based on the provided text, the submission is a "special 510(k)" to obtain market clearance for additional models of the device, implying that the fundamental device design and efficacy have been previously established.

Therefore, the "acceptance criteria" and "study" described herein refers specifically to the new models' performance relative to the predicate device, rather than a de novo clinical trial demonstrating the primary safety and effectiveness of interbody fusion devices in general.

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (for additional device models)	Reported Device Performance (for additional device models)
Mechanical performance of modified devices is substantially equivalent to the predicate device.	FEA Results: The Finite Element Analysis (FEA) results demonstrate that the performance of the modified device is substantially equivalent to that of the predicate.

2. Sample Size for the Test Set and Data Provenance

The text explicitly states: "Design verification testing was conducted via Finite Element Analysis (FEA) to assess the device modification."

Sample Size for the Test Set: This refers to the number of simulations/analyses performed in the FEA. The document does not specify a numerical sample size for the FEA. It implies a single, comprehensive FEA study comparing the modified designs to the predicate.
Data Provenance: This is not applicable in the traditional sense of patient data. The "data" here are the computational results from the Finite Element Analysis. As this is a simulation, there is no "country of origin" or "retrospective/prospective" aspect beyond the origin of the device manufacturer and the analysis itself.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

Not applicable. The "ground truth" for the performance of the modified device, in this context, is established through the engineering principles and computational models used in the Finite Element Analysis, and then compared to the known performance of the predicate device. There is no mention of experts establishing a ground truth in the context of interpreting patient data or clinical outcomes for this specific submission.

4. Adjudication Method for the Test Set

Not applicable. There is no clinical test set requiring adjudication. The assessment of substantial equivalence relies on the analytical results of the FEA.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

No, an MRMC comparative effectiveness study was not done. This submission is for additional models of an implantable medical device, and the performance assessment was conducted via Finite Element Analysis, not clinical (human reader) studies.

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

This question is typically relevant for AI/software as a medical device. For this implantable device, the closest equivalent is the Finite Element Analysis (FEA), which is a standalone computational simulation of the device's mechanical performance without human-in-the-loop interaction in the performance assessment itself. The analysis determines the mechanical properties of the device.

7. The Type of Ground Truth Used

The ground truth for this special 510(k) submission is the mechanical performance of the legally marketed predicate device (K152156). The FEA of the modified device is compared to this established performance to demonstrate substantial equivalence.

8. The Sample Size for the Training Set

Not applicable. This is not a machine learning model. The "training" for the Finite Element Analysis (if one were to use that analogy) would be the development and validation of the FEA model itself, which is a complex engineering task and not typically described in terms of a "training set sample size" in this context.

9. How the Ground Truth for the Training Set was Established

Not applicable. As above, this is not a machine learning context. The FEA models are developed based on established engineering principles, material properties (e.g., Ti-6Al-4V per ASTM F136), and validated against physical testing methods, but the document does not detail this specific validation process for the FEA model used.

Summary

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April 4, 2016

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

Interventional Spine, Incorporated Ms. Jane Metcalf Vice President, Quality Assurance, Regulatory and Clinical Affairs 13700 Alton Parkway, Suite 160 Irvine, California 92618

Re: K160464

Trade/Device Name: Opticage® Expandable Interbody Fusion Device Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: March 17, 2016 Received: March 18, 2016

Dear Ms. Metcalf:

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 Parts 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,

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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

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K160464

K160464 Page 1 of 1

Device Name

Opticage® Expandable Interbody Fusion Device

Indications for Use (Describe)

The Opticage® Expandable Interbody Fusion Device is a posterior lumbar intervertebral body fusion device and is indicated for use with autogenous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. These DDD patients may also have up to Grade I spondylolisthesis at the involved level(s). The Opticage Interbody Fusion Device can be implanted via posterior, transforaminal or lateral approach.

DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radios. Candidates for surgery should be skeletally mature and have had six months of conservative treatment. These patients may have had primary or secondary surgery, but no previous fusion at the involved levels.

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

☑ Prescription Use (Part 21 CFR 801 Subpart D)	□ Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary

APPLICANT:	Interventional Spine, Inc.
DATE PREPARED:	February 17, 2016
CONTACT PERSON:	Jane Metcalf13700 Alton Parkway, Ste 160Irvine, CA 92618Phone: 949.525.1493Fax: 949.472.0016
TRADE NAME:	Opticage® Expandable Interbody Fusion Device
COMMON NAME:	Interbody Fusion Device
CLASSIFICATION NAME:	Intervertebral Body Fusion Device
DEVICE CLASSIFICATION:	Class II
REGULATION NUMBER	888.3080 (product code: MAX)
PRIMARY PREDICATEDEVICE:	Opticage® Expandable Interbody Fusion Device (K152156)

Purpose of Submission

The purpose of this special 510(k) submission is to obtain market clearance for twenty-four (24) additional models of the Opticage Expandable Interbody Fusion Device.

Indication for Use and Intended Use

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510(k) Summary

Device Description

Technical Characteristics

The modified devices contain an 8 degree lordotic angle. Otherwise, they have the same physical and technological characteristics as the predicate devices.

Performance Tests

Design verification testing was conducted via Finite Element Analysis (FEA) to assess the device modification. The FEA results demonstrate that the performance of the device is substantially equivalent to that of the predicate.

Basis for Determination of Substantial Equivalence

The predicate and the modified devices have identical intended uses. They are fabricated from the same material, are supplied in the same manner, have identical operating mechanisms and similar technological characteristics. Differences between the predicate and modified device do not raise any additional issues of safety or effectiveness

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.