K Number
K190877
Device Name
Juliet® Ti LL Lumbar Interbody Device
Manufacturer
Date Cleared
2019-05-29

(55 days)

Product Code
Regulation Number
888.3080
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
JULIET® Ti LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). The JULIET® Ti LL Lumbar Interbody Device are to be used with autogenous and/or allogeneic bone graft comprised of cancellous and/or corticocancellous bone graft to facilitate fusion. Patients should have at least six (6) months of non-operative treatment with an intervertebral cage. Implants with 15-degree lordosis or greater are only indicated from levels L2-L5 and are to be used with at least two integrated fixation screws. The JULIET® Ti LL implants must be used with supplemental internal spinal fixation system that has been cleared by the FDA for use in the lumbosacral spine.
Device Description
Spineart Juliet® Ti LL spinal implants consist of a range of titanium intervertebral body spacers, implanted via a lateral approach, with various sizes and footprints so as to adapt different patient's conditions. The Juliet® Ti LL spinal implants are made of Titanium alloy Ti6Al4V ELI conforming to ASTM F136. The Juliet® Ti LL spinal implants are additively manufactured and present both solid and porous structures. The subject Product Line Extension consists of an extended range of titanium alloy spacers with integrated fixation. Juliet® Ti LL Product Line Extension also introduces a range of hyperlordotic intervertebral spacers of various sizes, heights, footprints and lordosis with the integrated fixation. The Juliet® Ti LL spinal implants are delivered sterile (gamma sterilization) and supplied with dedicated surgical instruments (reusable - provided non-sterile). Bacterial endotoxin testing as specified in USP standard is used for pyrogenicity testing to achieve the Endotoxin limit of 20 EU / device.
More Information

Not Found

No
The summary describes a physical interbody fusion device and its mechanical properties, with no mention of software, algorithms, or AI/ML capabilities.

Yes.
The device is indicated for intervertebral body fusion procedures to treat degenerative disc disease, which qualifies it as a therapeutic device aimed at treating a medical condition.

No

This device is an implantable lumbar interbody fusion device, designed to facilitate fusion in patients with degenerative disc disease, not to diagnose a condition.

No

The device description clearly states it is a range of titanium intervertebral body spacers, which are physical implants. It also mentions dedicated surgical instruments. This indicates a hardware-based medical device, not software-only.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for intervertebral body fusion. This is a therapeutic procedure performed in vivo (within the body).
  • Device Description: The device is described as a titanium intervertebral body spacer, which is a physical implant.
  • Lack of Diagnostic Function: There is no mention of the device being used to examine specimens derived from the human body to provide information for diagnostic purposes.

IVD devices are used to test samples like blood, urine, or tissue in vitro (outside the body) to diagnose diseases or conditions. This device is a surgical implant used to treat a condition directly within the body.

N/A

Intended Use / Indications for Use

JULIET® Ti LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). The JULIET® Ti LL Lumbar Interbody Device are to be used with autogenous and/or allogeneic bone graft comprised of cancellous and/or corticocancellous bone graft to facilitate fusion. Patients should have at least six (6) months of non-operative treatment with an intervertebral cage.

Implants with 15-degree lordosis or greater are only indicated from levels L2-L5 and are to be used with at least two integrated fixation screws. The JULIET® Ti LL implants must be used with supplemental internal spinal fixation system that has been cleared by the FDA for use in the lumbosacral spine.

Product codes (comma separated list FDA assigned to the subject device)

OVD, MAX

Device Description

Spineart Juliet® Ti LL spinal implants consist of a range of titanium intervertebral body spacers, implanted via a lateral approach, with various sizes and footprints so as to adapt different patient's conditions. The Juliet® Ti LL spinal implants are made of Titanium alloy Ti6Al4V ELI conforming to ASTM F136. The Juliet® Ti LL spinal implants are additively manufactured and present both solid and porous structures. The subject Product Line Extension consists of an extended range of titanium alloy spacers with integrated fixation. Juliet® Ti LL Product Line Extension also introduces a range of hyperlordotic intervertebral spacers of various sizes, heights, footprints and lordosis with the integrated fixation. The Juliet® Ti LL spinal implants are delivered sterile (gamma sterilization) and supplied with dedicated surgical instruments (reusable - provided non-sterile). Bacterial endotoxin testing as specified in USP standard is used for pyrogenicity testing to achieve the Endotoxin limit of 20 EU / device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

L2-S1 (lumbar spine, lumbosacral spine)

Indicated Patient Age Range

Skeletally mature patients

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

The following non-clinical tests were conducted on the Juliet® Ti LL: static and dynamic axial compression (per ASTM F2077), static and dynamic shear compression (per ASTM F2077), static and dynamic torsion (per ASTM F2077), expulsion, subsidence (per ASTM F2267) and mass loss determination after dynamic testing on assemblies (spacer + plate + fixation screws) that passed 5 million cycles. Results demonstrate comparable mechanical properties to the primary predicate device Scarlet® AL-T (K181818) manufactured by Spineart. Additionally, axial push out on the fixation screws through the plate has been conducted.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

Scarlet® AL-T (K181818), Juliet® Ti LL (K173702), Timberline® MPF (K163543)

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

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May 29, 2019

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Spineart Mr. Franck Pennesi Chief Technical Officer 3 chemin du pre Fleuri Plan Ouates, 1228 Ch

Re: K190877

Trade/Device Name: Juliet® Ti LL Lumbar Interbody Device Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: OVD, MAX Dated: April 2, 2019 Received: April 4, 2019

Dear Mr. Pennesi:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for

1

devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

for

CAPT Raquel Peat, PhD, MPH, USPHS Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known) K190877

Device Name

JULIET® Ti LL Lumbar Interbody Device

Indications for Use (Describe)

JULIET® Ti LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). The JULIET® Ti LL Lumbar Interbody Device are to be used with autogenous and/or allogeneic bone graft comprised of cancellous and/or corticocancellous bone graft to facilitate fusion. Patients should have at least six (6) months of non-operative treatment with an intervertebral cage.

Implants with 15-degree lordosis or greater are only indicated from levels L2-L5 and are to be used with at least two integrated fixation screws. The JULIET® Ti LL implants must be used with supplemental internal spinal fixation system that has been cleared by the FDA for use in the lumbosacral spine.

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

[ ] Over-The-Counter Use (21 CFR 801 Subpart C) > Prescription Use (Part 21 CFR 801 Subpart D)

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510(k) SUMMARY

510kTRADITIONAL
Basis for submissionNEW DEVICES -LINE EXTENSION
Submitted bySPINEART
3 Chemin du Pré Fleuri 1228 PLAN LES OUATES
GENEVA SWITZERLAND
ContactsFranck PENNESI Chief Technical Officer
Phone: +41 22 570 1200 Fax: +41 22 594 8306
Mail: fpennesi@spineart.com
Regulatory contact: Dr Isabelle DRUBAIX (Idée Consulting) idrubaix@nordnet.fr
Date PreparedMarch 26, 2019
Common NameIntervertebral body fusion device
Trade NameJULIET® Ti LL Lumbar Interbody Device
Classification NameIntervertebral Fusion Device with Integrated Fixation Lumbar / Intervertebral Fusion Device Lumbar
ClassII
Product CodeOVD / MAX
CFR section888.3080
Device panelORTHOPEDIC
Legally marketed predicate devicesPrimary predicate: Scarlet® AL-T (K181818) manufactured by Spineart
Additional predicates: Juliet® Ti LL (K173702) manufactured by Spineart and Timberline® MPF (K163543) manufactured by Zimmer Biomet
Indications for useJULIET® Ti LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). The JULIET® Ti LL Lumbar Interbody Device are to be used with autogenous and/or allogeneic bone graft comprised of cancellous and/or corticocancellous bone graft to facilitate fusion. Patients should have at least six (6) months of non-operative treatment prior to treatment with an intervertebral cage. Implants with 15-degree lordosis or greater are only indicated from levels L2-L5 and are to be used with at least two integrated fixation screws. The JULIET® Ti LL implants must be used with supplemental internal spinal fixation system that has been cleared by the FDA for use in the lumbosacral spine
Description of the deviceSpineart Juliet® Ti LL spinal implants consist of a range of titanium intervertebral
body spacers, implanted via a lateral approach, with various sizes and footprints so
as to adapt different patient's conditions. The Juliet® Ti LL spinal implants are made
of Titanium alloy Ti6Al4V ELI conforming to ASTM F136. The Juliet® Ti LL spinal
implants are additively manufactured and present both solid and porous structures.
The subject Product Line Extension consists of an extended range of titanium alloy
spacers with integrated fixation. Juliet® Ti LL Product Line Extension also introduces
a range of hyperlordotic intervertebral spacers of various sizes, heights, footprints
and lordosis with the integrated fixation.
The Juliet® Ti LL spinal implants are delivered sterile (gamma sterilization) and
supplied with dedicated surgical instruments (reusable - provided non-sterile).
Bacterial endotoxin testing as specified in USP standard is used for pyrogenicity
testing to achieve the Endotoxin limit of 20 EU / device.
Technological
characteristics
compared to
predicate devicesThe added Juliet® Ti LL implants present similar design features, solid, lattice and
porous structures, the same manufacturing technology, i.e. additive manufacturing
(SLM) and the same material, i.e. titanium alloy conforming to ASTM F136 identically
to Juliet® Ti LL (K173702).
The previously cleared Juliet® Ti LL (K173702) and added hyperlordotic interbody
spacers can be implanted in a configuration with integrated fixation provided by the
mean of titanium alloy plate that come in various shapes, and heights and fixation
screws that come in various diameters and lengths so as to better fulfil surgeon's
needs and to accommodate varying patient anatomy. The bone screws are secured
by the mean of a cover-plate that prevent backing out.
Juliet® Ti LL implants conform to the Guidance for Industry and Food and Drug
Administration Staff issued on December 5, 2017 "Technical Considerations for
Additive Manufactured Devices".
As was established in this submission added Scarlet® AC-T fixation screws are
substantially equivalent and has the same technological and mechanical
characteristics to predicate devices.
Discussion of TestingThe following non-clinical tests were conducted on the Juliet® Ti LL: static and
dynamic axial compression (per ASTM F2077), static and dynamic shear
compression (per ASTM F2077), static and dynamic torsion (per ASTM F2077),
expulsion, subsidence (per ASTM F2267) and mass loss determination
after dynamic testing on assemblies (spacer + plate + fixation screws) that passed 5
million cycles. Results demonstrate comparable mechanical properties to the
primary predicate device Scarlet® AL-T (K181818) manufactured by Spineart.
Additionally, axial push out on the fixation screws through the plate has
been conducted.
ConclusionBased on the design features, technological characteristics, feature comparisons,
indications for use, and non-clinical performance testing, the added Juliet® Ti LL
devices have demonstrated substantial equivalence to the identified predicate
devices

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