The MectaLIF Anterior is an anterior interbody fusion device in patients with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The interior of the spacer component of the MectaLIF Anterior System can be packed with autograft or autologous bone graft. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment. These patients may have had a previous non-fusion spinal surgery at the involved spinal level(s). The MectaLIF Anterior Stand-Alone system intended to be used with bone screws provided and requires no additional supplementary fixation. The MectaLIF Anterior Simple requires additional supplementary fixation such as pedicle screws and rods or lumbar anterior plate system.

Device Description

The MectaLIF Anterior Simple devices are interbody fusion devices which require supplementary fixation such as pedicle screws and rods or a lumbar anterior plate system. The design incorporates the benefits of a modular anterior plate and a radiolucent interbody spacer; the plate is secured to the disc spacer via an interlocking mechanism. The plates, manufactured from Ti6A14V ELI (ISO 5832-3 and ASTM F136), are provided sterile and are offered in five (5) heights (10 - 18 mm). The spacers, cleared under K124034, K160605, and K170455, are manufactured from PEEK and Ti-PEEK.

AI/ML Overview

This FDA 510(k) summary for the MectaLIF Anterior Simple device does not contain the specific information requested regarding acceptance criteria and a study proving the device meets those criteria in the context of device performance related to diagnostic or clinical outcomes from a study. Instead, it outlines the regulatory basis for substantial equivalence for an intervertebral body fusion device.

The "Performance Data" section describes mechanical and material testing of the device components, not a clinical study to assess its diagnostic accuracy or clinical efficacy against predefined acceptance criteria for patient outcomes.

Therefore, many of the requested items cannot be extracted from the provided text.

Here is a breakdown of what can and cannot be extracted:

1. Table of Acceptance Criteria and Reported Device Performance

Cannot be provided as requested.
The document describes mechanical tests performed on the device components (plates), not clinical performance metrics with defined acceptance criteria. The tests listed (static/dynamic axial compression, compression-shear, torsion, subsidence, expulsion) are engineering benchmarks to ensure structural integrity and safety, not measures of clinical outcomes or diagnostic accuracy.

Acceptance Criteria (e.g., Sensitivity, Specificity)	Reported Device Performance
Not applicable (no clinical performance evaluation)	Not applicable

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

Cannot be provided.
No clinical "test set" (i.e., a cohort of patients or samples used for a clinical performance study) is mentioned. The "worst-case device" for mechanical testing implies a limited number of physical samples for engineering evaluation.

3. Number of Experts Used to Establish Ground Truth and Qualifications

Cannot be provided.
No expert review or ground truth establishment relevant to clinical outcomes is described.

4. Adjudication Method for the Test Set

Cannot be provided.
No clinical test set or adjudication process is mentioned.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

Cannot be provided.
No such study is mentioned. The device is a physical intervertebral fusion device, not a diagnostic AI system that would typically be evaluated with MRMC studies comparing human readers with and without AI assistance.

6. Standalone Performance (Algorithm Only)

Cannot be provided.
Not applicable as this is a physical medical device, not an algorithm or AI system.

7. Type of Ground Truth Used

Cannot be provided.
No ground truth in the context of clinical outcomes, pathology, or expert consensus is discussed. The "performance data" refers to results from mechanical testing, where the "truth" is adherence to industry standards and the device's physical properties.

8. Sample Size for the Training Set

Cannot be provided.
Not applicable. No "training set" in the context of machine learning or clinical data is mentioned.

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

Cannot be provided.
Not applicable.

Summary of Available Information from the Provided Text:

The document focuses on demonstrating substantial equivalence for the MectaLIF Anterior Simple interbody fusion device to its predicate devices based on:

Technological Characteristics Comparison: Similarities in size, materials, biocompatibility, usage, sterilization, shelf life, and packaging. The key difference is that the "Simple" version requires supplementary fixation and does not include bone screws, unlike the "Stand-Alone" predicates.
Performance Data (Mechanical Testing):
- The MectaLIF Anterior plates were tested according to ASTM F2077-11, ASTM F2267-04 (reapproved 2011), ASTM F1877-05 (reapproved 2010), and ISO 17853:2011.
- Tests included: static axial compression, dynamic axial compression, static compression-shear, dynamic compression-shear, static torsion, dynamic torsion, subsidence, and expulsion.
- Worst-case analysis determined that the MectaLIF Anterior Simple does not introduce a new worst-case plate compared to previously cleared plates (K124034), thus requiring no additional verification testing for these aspects.
- Biocompatibility/Safety Testing: Bacterial Endotoxin Test (LAL test) according to European Pharmacopoeia §2.6.14 (equivalent to USP <85>) and pyrogen test according to USP <151>.

This FDA submission is for a physical implantable device, and the "performance data" section details engineering and safety tests rather than a clinical study evaluating diagnostic or treatment efficacy using human subjects. Therefore, many of the requested AI/diagnostic study related fields are not applicable.

Summary

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March 9, 2020

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: on the left, there is a seal with an abstract design, and on the right, there is the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue. The text is arranged in three lines, with "FDA" in a larger font and enclosed in a blue square.

Medacta International SA % Chris Lussier Director, Quality and Regulatory Medacta USA 3973 Delp Street Memphis, Tennessee 38118

Re: K200048

Trade/Device Name: MectaLIF Anterior Simple Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: January 6, 2020 Received: January 9, 2020

Dear Mr. Lussier:

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

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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

Brent L. Showalter, Ph.D. Assistant Director (Acting) 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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Indications for Use

510(k) Number (if known)

K200048

Device Name MectaLIF Anterior Simple

Indications for Use (Describe)

The MectaLF Anterior is an anterior interbody fusion device in patients with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The interior of the spacer component of the MectaLIF Anterior System can be packed with autograft or autologous bone graft. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had six months of non-operative treatment. These patients may have had a previous non-fusion spinal surgery at the involved spinal level(s). The MectaLIF Anterior Stand-Alone system intended to be used with bone screws provided and requires no additional supplementary fixation. The MectaLIF Anterior Simple requires additional supplementary fixation such as pedicle screws and rods or lumbar anterior plate system.

X Prescription Use (Part 21 CFR 801 Subpart D)

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

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2.0 510(k) Summary

I. Submitter

Medacta International SA Strada Regina 6874 Castel San Pietro (CH) Switzerland Phone (+41) 91 696 60 60 Fax (+41) 91 696 60 66

Contact Person: Stefano Baj, Regulatory and Compliance Director, Medacta International SA Applicant Correspondent: Chris Lussier, Director, Quality and Regulatory, Medacta USA Date Prepared: January 6, 2020 Date Revised: February 24, 2020

II. Device

Device Proprietary Name:	MectaLIF Anterior Simple
Common or Usual Name:	Anterior Intervertebral Body Fusion Device
Classification Name:	Intervertebral Fusion Device With Bone Graft,Lumbar
Primary Product Code:	MAX
Regulation Number:	21 CFR 888.3080
Device Classification	II

III. Predicate Device

Substantial equivalence is claimed to the following device:

. Primary Predicate: MectaLIF Anterior, K124034, Medacta International SA
The following are additional predicate devices:
MectaLIF Anterior Stand Alone, K160605, Medacta International SA
. MectaLIF Anterior Stand Alone, K170455, Medacta International SA

IV. Device Description

The plates, manufactured from Ti6A14V ELI (ISO 5832-3 and ASTM F136), are provided sterile and are offered in five (5) heights (10 - 18 mm).

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The spacers, cleared under K124034, K160605, and K170455, are manufactured from PEEK and Ti-PEEK.

V. Indications for Use

The MectaLIF Anterior is an anterior interbody fusion device indicated for use in patients with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The interior of the spacer component of the MectaLIF Anterior System can be packed with autograft or autologous bone graft. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies.

These patients should be skeletally mature and have had six months of non-operative treatment. These patients may have had a previous non-fusion spinal surgery at the involved spinal level(s).

The MectaLIF Anterior Stand-Alone system is a system intended to be used with bone screws provided and requires no additional supplementary fixation. The MectaLIF Anterior Simple requires additional supplementary fixation such as pedicle screws and rods or lumbar anterior plate system.

VI. Comparison of Technological Characteristics

The MectaLIF Anterior Simple and the predicate device share the following characteristics:

size; ●
materials of construction;
biocompatibility; ●
device usage: ●
sterilization method; ●
shelf life; and
packaging.

The MectaLIF Anterior Simple and the predicate devices are technologically different as the subject devices are not stand-alone products; therefore, they are not provided with bone screws and supplementary fixation is required.

Performance Data VII.

The MectaLIF Anterior plates were tested per ASTM F2077-11, ASTM F2267-04 (reapproved 2011), ASTM F1877-05 (reapproved 2010), and ISO 17853:2011 using the worst-case device for each of the following tests:

static axial compression;
. dynamic axial compression:

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static compression-shear; ●
dynamic compression-shear;
static torsion;
dynamic torsion;
. subsidence; and
expulsion.

In addition, the Bacterial Endotoxin Test (LAL test) was conducted according to European Pharmacopoeia §2.6.14 (which is equivalent to USP chapter <85>) and pyrogen test according to USP chapter <151> for pyrogenicity determination.

Worst-case analysis was conducted on the MectaLIF Anterior plate family. It was determined that the MectaLIF Anterior Simple does not introduce new worst-case plate when compared to the previously cleared plates (K124034); therefore, additional verification testing is not required.

VIII. Conclusion

The information provided above supports that the MectaLIF Anterior Simple plates are substantially equivalent to the identified 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.