Elite™ Expandable implants are intervertebral body fusion devices indicated for intervertebral body fusion at one level or two contiguous levels in the lumbar spine from L2 to S1 in patients with degenerative disc disease (DDD) with up to Grade 1 spondylolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment.

Elite™ Expandable implants are designed for use with autograft comprised of cancellous and/or corticocancellous bone graft as an adjunct to fusion and are intended for use with supplemental fixation systems cleared by the FDA for use in the lumbar spine.

Device Description

The Elite™ Expandable Interbody Fusion System is designed for use as a lumbar intervertebral body fusion device and consists of medical grade titanium alloy (Ti-6AL-4V, ELI) cages and implantation instrumentation. The cages are available in various geometries and sizes to accommodate patient anatomy. The cages have ridges or teeth that resist rotation and migration and have cavities to accept packing of bone graft. Components of the Elite™ IBF Expandable Lumbar Fusion System should not be used with components of any other system or manufacturer.

AI/ML Overview

This document does not contain information about acceptance criteria, device performance metrics, or a study specifically designed to establish acceptance criteria for the Elite™ Expandable Interbody Fusion Device.

The document is an FDA 510(k) clearance letter and a 510(k) summary for the Elite™ Expandable Interbody Fusion Device. It primarily focuses on demonstrating substantial equivalence to legally marketed predicate devices, not on proving that the device meets specific performance acceptance criteria through a clinical study or detailed non-clinical performance report.

Here's what can be extracted from the document:

1. Table of Acceptance Criteria and Reported Device Performance:

This information is not provided in the document. The document lists mechanical tests performed (ASTM F2077, F2267) and bacterial endotoxin testing, but it does not specify quantitative acceptance criteria for these tests nor does it report specific numeric results against those criteria. It only states that these tests were "conducted in accordance with FDA's Class II Special Controls Guidance Document... and applicable American Society for Testing and Materials (ASTM) standards." This implies the tests were performed to demonstrate mechanical integrity and biocompatibility, but the specific performance values and acceptable ranges are not disclosed.

2. Sample Size Used for the Test Set and Data Provenance:

Test Set Sample Size: Not applicable as no specific clinical or performance test set (in the context of real-world patient data or detailed device performance metrics) is described in terms of a sample size. The "test set" here refers to the physical devices subjected to mechanical testing.
Data Provenance: The document refers to non-clinical mechanical testing and bacterial endotoxin testing. This is laboratory-based testing, not clinical data from patients.

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

Not applicable. The document describes mechanical and biocompatibility testing of the device, not a study evaluating human interpretation or diagnosis. Therefore, there's no "ground truth" established by experts in the context of diagnostic performance.

4. Adjudication Method:

Not applicable. There's no adjudication method mentioned as this document does not describe a study involving expert review or interpretation.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, Effect Size:

No. An MRMC comparative effectiveness study was not done. This type of study typically assesses the performance of human readers (e.g., radiologists) with and without AI assistance, which is not relevant to this mechanical device submission.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:

Not applicable. This is a physical intervertebral body fusion device, not an algorithm or AI software. Therefore, "standalone performance" in the context of an algorithm is not relevant.

7. Type of Ground Truth Used:

Not applicable in the context of diagnostic or interpretive performance. For the mechanical and biocompatibility testing, the "ground truth" would be established by the physical properties of the materials and the manufacturing process, verified by standardized laboratory tests.

8. Sample Size for the Training Set:

Not applicable. This is a physical medical device, not an AI/ML algorithm that requires a training set.

9. How the Ground Truth for the Training Set Was Established:

Not applicable for the same reason as point 8.

Summary

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

January 27, 2017

Spineology Inc. Ms. Jacqueline Hauge Regulatory Affairs Manager 7800 3rd Street North, Suite 600 St. Paul. Minnesota 55127

Re: K162879

Trade/Device Name: Elite™ Expandable Interbody Fusion Device Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: December 21, 2016 Received: December 22, 2016

Dear Ms. Hauge:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set 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.

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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/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Mark N. Melkerson -S

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)

K162879

Device Name

Elite™Expandable Interbody Fusion Device

Indications for Use (Describe)

Elite™ Expandable implants are intervertebral body fusion devices indicated for intervertebral body fusion at one level or two contiguous levels in the lumbar spine from L2 to S1 in patients with degenerative disc disease (DDD) with up to Grade 1 spondylolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. These patients should be sketally mature and have had six months of non-operative treatment.

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

Date Prepared:	December 21, 2016
Submitter:	Spineology Inc.7800 3rd Street North, Suite 600Saint Paul, MN 55128Establishment Registration Number: 2135156
Contact Person:	Jacqueline A. HaugeRegulatory Affairs MangerPhone: 651.256.8534 Fax: 651.256.8505Email: jhauge@spineology.com
Device Name and Classification
Trade Name:	Elite™ Expandable Interbody Fusion Device
Common Name:	Spinal implant
Classification Name:	Intervertebral body fusion device
Product Codes:	MAX
Regulatory Class:	Class II
Regulation Number:	21 CFR 888.3080

Orthopedic

Predicate DevicesPrimary:	K133459	Elite™ Interbody Fusion Device (Innova Spinal Technologies, LLC)
Additional:	K160906	Rampart™ O Lumbar Interbody Fusion Device (Spineology Inc.);Rampart™ T Lumbar Interbody Fusion Device (Spineology Inc.);Rampart™ A Lumbar Interbody Fusion Device (Spineology Inc.)
	K102293	Caliber® Spacer (Globus Medical Inc.)
	K113527	Opticage® Expandable Interbody Fusion Device (Interventional Spine, Inc.)

I. Purpose

Panel:

The purpose of this submission is to obtain FDA clearance of the Spineology Elite™ Expandable Interbody Fusion Device which is comprised of 10mm and 12mm Elite™ Expandable implantable devices and associated surgical instrumentation.

II. Previous Submissions

510(k) #	Device Name	Purpose of 510(k)
K133459	12mm Elite™ Interbody Fusion Device	Initial Clearance
K150954	12mm Elite™ L Interbody Fusion Device	Added Device

No previous submissions have been submitted for the 10mm Elite™ Expandable device.

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K162879 page 2 of 2

510(k) Summary

III. Device Description

IV. Indications for Use

Elite™ Expandable implants are designed for use with autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft as an adjunct to fusion and are intended for use with supplemental fixation systems cleared by the FDA for use in the lumbar spine.

V. Technological Characteristics

Elite™ Expandable implants have the same technological characteristics as the predicate Elite Interbody Fusion Device, including design, intended use, material composition, and function.

VI. Non-Clinical Testing

The following mechanical testing was conducted in accordance with FDA's Class II Special Controls Guidance Document: Intervertebral Fusion Device (2007) and applicable American Society for Testing and Materials (ASTM) standards:

ASTM F2077

ASTM F2267 • Static and Dynamic Axial Compression · Subsidence • Static and Dynamic Compression Shear
Expulsion • Static Torsion

Bacterial endotoxin testing (BET) was conducted in accordance with ANSI/AAMI ST-72:2011.

VII. Conclusion

Based on the indications for use, technological characteristics, and comparison to the predicate devices, the Elite™ Expandable Interbody Fusion System has been shown to be substantially equivalent to legally marketed predicate devices.

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.