When used in the cervical spine (C2-T1), F3D Corpectomy devices are intended for use in skeletally mature patients to replace a diseased or damaged vertebral body caused by tumor fracture or osteomyelitis, or for reconstruction following corpectomy performed to achieve decompression of the spinal cord and neural tissues in cervical degenerative disorders. These spacers are intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion, with bone graft used at the surgeon's discretion.

When used in the thoracolumbar spine (T1-L5), F3D Corpectomy devices are intended for use to replace a collapsed, damaged, or unstable vertebral body due to tumor or trauma (i.e., fracture). These spacers are designed to provide anterior spinal column support even in the absence of fusion for a prolonged period.

The interior of the spacers can be packed with autograft or allogenic bone graft comprising cancellous and/or corticocancellous bone graft and/or demineralized allograft bone with bone marrow aspirate as an adjunct to fusion.

These devices are intended to be used with FDA-cleared supplemental spinal fixation systems that have been labeled for use in the cervical, thoracic, and/or lumbar spine (i.e., posterior screw and rod systems, anterior plate systems, and anterior screw and rod systems). When used at more than two levels, supplemental fixation should include posterior fixation.

Device Description

The F3D Corpectomy Cage is a spinal vertebral body replacement device which is available in a variety of different heights, footprints, and lordotic options to suit the individual pathology and anatomical conditions of the patient. The F3D Corpectomy cage consists of a static, single-piece vertebral body replacement cage. The F3D Corpectomy devices are intended for use in the cervical (C2-T1) and thoracolumbar spine (T1-L5). They are designed to provide mechanical support to the spine while arthrodesis occurs. The F3D Corpectomy System is made from titanium alloy (Ti-6Al-4V) per ASTM F3001.

AI/ML Overview

The FDA 510(k) summary for the F3D Corpectomy System (K202637) focuses on establishing substantial equivalence to predicate devices through technical characteristics and mechanical performance testing, rather than an AI/ML context. Therefore, many typical AI/ML study components (like expert ground truth, adjudication, MRMC studies, training set details) are not applicable or mentioned.

Here's an analysis of the provided text, outlining the acceptance criteria and the study performed, along with the information that is not available given the nature of this medical device clearance (spinal implant, not an AI/ML device):

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state numerical acceptance criteria in the format of a table with specific thresholds. Instead, it refers to industry standards (ASTM F2077 and ASTM F2267) and concludes that the device's strength is "sufficient for its intended use" and "substantially equivalent to legally marketed predicate devices."

Acceptance Criteria (Implied)	Reported Device Performance
Mechanical Strength (Static Axial Compression)	Tested per ASTM F2077. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Mechanical Strength (Static Torsion)	Tested per ASTM F2077. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Mechanical Strength (Dynamic Axial Compression)	Tested per ASTM F2077. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Mechanical Strength (Dynamic Torsion)	Tested per ASTM F2077. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Resistance to Subsidence	Tested per ASTM F2267. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Resistance to Expulsion	Tested. Results showed the strength was sufficient for its intended use and substantially equivalent to predicate devices.
Biocompatibility	Stated as "identical" to predicate devices, implying it meets established biocompatibility standards.
Sterilization	Stated as "identical" to predicate devices, implying it meets established sterilization standards.
Material Composition (Ti-6Al-4V per ASTM F3001)	Confirmed; stated as "identical" to predicate devices, implying it meets material property requirements.
Technological Characteristics & Structural Support Mechanism	Stated as "nearly identical" to predicate devices, with minor differences not raising new safety/effectiveness issues.
Sizes	Stated as "identical" to predicate devices, implying it falls within expected dimensions for spinal implants.
Indications for Use	Stated as "identical" to predicate devices. This implies the device safely and effectively serves the specified purposes (vertebral body replacement for tumor, trauma, degenerative disorders).

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

Sample Size: Not explicitly stated as a number of devices. The tests are typically performed on a statistically relevant number of physical device samples as required by the ASTM standards, but the exact count is not disclosed in the summary.
Data Provenance: The tests are non-clinical, meaning they were performed in a laboratory setting ("Performance Data" section). There is no mention of patient data (retrospective or prospective) or country of origin for such data, as this is a mechanical safety and performance study for a physical implant.

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

This information is not applicable as the evaluation is based on mechanical laboratory testing against industry standards, not on interpretation of medical images or patient outcomes requiring expert consensus.

4. Adjudication Method for the Test Set

This information is not applicable as there is no human interpretation or decision-making process for the mechanical test results that would require adjudication.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs without AI Assistance

This information is not applicable. The F3D Corpectomy System is a physical spinal implant, not an AI/ML-driven diagnostic or assistive device that would involve human readers.

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

This information is not applicable. The device is a physical implant and does not involve an algorithm.

7. The Type of Ground Truth Used

The "ground truth" for this device, in a mechanical testing context, is adherence to established industry-wide performance standards (ASTM F2077 for static/dynamic compression and torsion, ASTM F2267 for subsidence) and demonstrating equivalency to already-cleared predicate devices. These standards represent scientifically validated methodologies for assessing the mechanical robustness and safety of spinal implants.

8. The Sample Size for the Training Set

This information is not applicable as the device is not an AI/ML product and does not involve a training set.

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

This information is not applicable as the device is not an AI/ML product and does not involve a training set.

Summary

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health and Human Services logo on the left, and the FDA acronym along with the full name of the agency on the right. The FDA part of the logo is in blue, with the acronym in a square and the full name written out to the right of the square. The full name of the agency is "U.S. Food & Drug Administration".

January 21, 2021

CoreLink, LLC % Nathan Wright, M.S. Engineer & Regulatory Specialist Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K202637

Trade/Device Name: F3D Corpectomy System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: MQP, PLR

Dear Mr. Wright:

The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated December 23, 2020. Specifically, FDA is updating this SE Letter as an administrative correction.

Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Brent Showalter, Ph.D., OHT6: Office of Orthopedic Devices, (240) 402-1840, Brent.Showalter@fda.hhs.gov.

Sincerely,

Brent Showalter -S

Brent L. Showalter, Ph.D. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Image /page/1/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" in a square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION".

December 23, 2020

CoreLink, LLC % Nathan Wright, M.S. Engineer & Regulatory Specialist Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K202637

Trade/Device Name: F3D Corpectomy System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: MQP, PLR Dated: November 20, 2020 Received: November 23, 2020

Dear Mr. Wright:

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.

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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 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.

Brent Showalter -S

Brent L. Showalter, Ph.D. Assistant 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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4. INDICATIONS FOR USE STATEMENT

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 on last page.

510(k) Number (if known) K202637

Device Name

F3D Corpectomy System

Indications for Use (Describe)

The F3D Corpectomy devices are vertebral body replacement devices intended for use in the cervical (C2-T1) and thoracolumbar spine (T1-L5).

When used in the cervical spine (C2-T1), F3D Corpectomy devices are intended for use in skeletally mature patients to replace a diseased or damaged vertebral body caused by tumor fracture or osteomvelitis, or for reconstruction following corpectomy performed to achieve decompression of the spinal cord and neural tissues in cervical degenerative disorders. These spacers are intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion, with bone graft used at the surgeon's discretion.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995. DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW. The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number. "

FORM FDA 3881 (7/17)

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510(K) SUMMARY

Submitter's Name:	CoreLink, LLC
Submitter's Address:	2072 Fenton Logistics Park Blvd.St. Louis, Missouri 63026
Submitter's Telephone:	888-349-7808
Contact Person:	Nathan Wright MSEmpirical Testing Corp.719-351-0248nwright@empiricaltech.com
Date Summary was Prepared:	September 10, 2020
Trade or Proprietary Name:	F3D Corpectomy System
Common or Usual Name:	Spinal Vertebral Body Replacement Device
Classification:	Class II per 21 CFR §888.3060
Regulation Name:	Spinal Intervertebral Body Fixation Orthosis
Product Code:	MQP, PLR
Classification Panel:	Orthopedics

DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

INDICATIONS FOR USE

The F3D Corpectomy devices are vertebral body replacement devices intended for use in the cervical (C2-T1) and thoracolumbar spine (T1-L5).

When used in the thoracolumbar spine (T1-L5), F3D Corpectomy devices are intended for use to replace a collapsed, damaged, or unstable vertebral body due to tumor or trauma (i.e., fracture).

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These spacers are designed to provide anterior spinal column support even in the absence of fusion for a prolonged period.

TECHNOLOGICAL CHARACTERISTICS

The subject and predicate devices have nearly identical technological characteristics and the minor differences do not raise any new issues of safety and effectiveness. Specifically, the following characteristics are identical between the subject and predicates:

Indications for Use
Materials of manufacture ●
Technological Characteristics and Structural support mechanism .
Sizes ●
Sterilization ●
Biocompatibility ●
Mechanical Strength ●

The use of demineralized allograft bone with bone marrow aspirate packing has not been identified in a cleared predicate with indications for vertebral body replacement. The use of demineralized allograft bone with bone marrow aspirate packing was cleared in the reference device K191581.

510k Number	Trade or Proprietary orModel Name	Manufacturer	PredicateType
K183588	HAWKEYE™ VertebralBody Replacement (VBR)	Choice Spine	Primary
K191778	Omnia Medical VBR	Omnia Medical, LLC	Additional
K180665	SANTORINI CorpectomyCage System	K2M, LLC	Additional
K191581	Endoskeleton® TLInterbody Fusion Device	Titan Spine, Inc.	Reference
K180556	Foundation 3D AnteriorLumbar System	CoreLink, LLC	Reference

Table 5-1 Predicate Devices

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Performance Data

The F3D Corpectomy System has been tested in the following test modes:

Static axial compression per ASTM F2077 ●
Static torsion per ASTM F2077 ●
Dynamic axial compression per ASTM F2077 ●
Dynamic torsion per ASTM F2077 ●
Subsidence per ASTM F2267 ●
Expulsion .

The results of this non-clinical testing show that the strength of the F3D Corpectomy System is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the F3D Corpectomy System is substantially equivalent to the predicate device.

Regulation Number and Section

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.