The PERLA® TL system is intended to provide immobilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine:

· degenerative disc disease;
· spondylolisthesis;
· fracture;
· dislocation;
scoliosis;
· kyphosis;
spinal tumor:
· and failed previous fusion (pseudarthrosis).

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the PERLA® TL system is indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The PERLA® TL system is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

When used in conjunction with TEKTONA® HV US bone cement system, the PERLA®TL system is intended to restore the integrity of the spinal column even in the absence of fusion for a limited period of time, in patients whom life expectancy is of insufficient duration to permit achievement of fusion in advanced stage of thoracic and lumbar spine tumors. The PERLA®TL 35mm to 60mm lengths Screws augmented used with TEKTONA® HV US bone cement system are intended to be used at spinal levels where the structural integrity is not severely compromised.

TEKTONA® HV US Bone Cement is indicated for the treatment of pathological fractures of the vertebral body using a vertebroplasty or kyphoplasty procedure. Painful vertebral compression fractures may result from osteoporosis, benign lesions (hemangioma), and malignant lesions (metastatic cancers, myeloma).

When used in conjunction with PERLA®TL system, TEKTONA® HV US Bone Cement is intended to restore the integrity of the spinal column even in the absence of fusion for a limited time in patients with advanced stage tumors involving the thoracic and lumbar spine in whom life expectancy is of insufficient duration to permit achievement of fusion. PERLA®TL Screws augmented with TEKTONA® HV US Bone Cement are for use at spinal levels where the structural integrity of the spine is not severely compromised.

Device Description

The PERLA® TL System consists of a range of screws, rods, set screws, hooks, rod connectors and cross-connectors. These connecting components can be rigidly locked to the rod in a variety of configurations to be adapted for the individual case. The PERLA® TL System is manufactured from medical grade titanium alloy and medical grade cobalt chromium conforming respectively to standards ASTM F136 and ASTM F1537.

The PERLA® TL System is identical to the previously cleared version, however this submission includes the additional option to use bone cement with the fenestrated screws.

Mendec Spine HV System (TEKTONA HV US Bone Cement) is highly viscous, radio-opaque acrylic resins (PMMA based) for percutaneous vertebroplasty or kyphoplasty. Mendec Spine HV System holds the powder and liquid components separately within a closed syringe-like device that serves as a mixing chamber. The device is packaged in unitary PVC-blister with tray, sealed with Tyvek lid, which is placed in an aluminum bag. The device is sold disposable and sterile.

AI/ML Overview

The provided FDA 510(k) summary (K230774) describes a medical device, the PERLA® TL System, and its use in conjunction with TEKTONA® HV US Bone Cement. However, this document does not contain acceptance criteria or a study describing the device's performance against such criteria for the PERLA® TL System with bone cement augmentation for thoracic and lumbar spine tumors.

The document states that:

"Bone cement usability testing (Usability Testing, Cement Injection Time Testing, and Cement Flow, Bolus Formation, and Screw Removal from Bone Cement Testing) was conducted to validate the use of the Perla® TL System used with bone cement."

And:

"The non-clinical tests performed by the company included bone cement usability testing and screw removal testing was conducted to validate the use of the Perla® TL System used with bone cement."

This indicates that testing was performed, but the details required to answer your specific questions (acceptance criteria, performance results, sample size, type of ground truth, expert qualifications, etc.) are not present in this document. The provided text focuses on establishing substantial equivalence to predicate devices based on indications, design, materials, manufacturing, and performance based on these "usability" and "screw removal" tests, but it does not quantify their results or define specific acceptance criteria they met.

Therefore, I cannot provide the requested table or detailed information about the study from the given text.

In summary, the provided document lacks the specific information about acceptance criteria and detailed study results that you are requesting.

Summary

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June 23, 2023

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 is 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 % Michael Coladonato Senior Associate, Spine Regulatory Affairs Mcra LLC 803 7th Street Northwest Third Floor Washington, District of Columbia 20001

Re: K230774

Trade/Device Name: PERLA® TL System; TEKTONA® HV US Bone Cement Regulation Number: 21 CFR 888.3027 Regulation Name: Polymethylmethacrylate (PMMA) Bone Cement Regulatory Class: Class II Product Code: PML, NKB, KWP Dated: May 26, 2023 Received: May 26, 2023

Dear Michael Coladonato:

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

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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 medical devices and radiation-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,

Image /page/1/Picture/5 description: The image contains the text "Colin O'neill -S" on the left side of the image. On the right side of the image is the letters "FDA" in a light blue color. The text is arranged in two lines, with "Colin" on the first line and "O'neill -S" on the second line. The text is in a simple, sans-serif font.

Colin O'Neill, M.B.E. 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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Indications for Use

510(k) Number (if known) K230774

Device Name Perla® TL System

Indications for Use (Describe)

· degenerative disc disease;
· spondylolisthesis;
· fracture;
· dislocation;
scoliosis;
· kyphosis;
spinal tumor:
· and failed previous fusion (pseudarthrosis).

When used for posterior non-cervical pedictic patients, the PERLA® TL system is indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The PERLA® TL system is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

When used in conjunction with TEKTONA® HV US bone cement system, the PERLA®TL system is intended to restore the integrity of the spinal column even in the absence of fusion for a limited period of time, in patients whom life expectancy is of insufficient duration to permit achievement of fusion in advanced stage of thoracic and lumbar spine tumors. The PERLA@TL 35mm to 60mm lengths Screws augmented used with TEKTONA® HV US bone cement system are intended to be used at spinal levels where the structural integrity is not severely compromised.

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

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Indications for Use

510(k) Number (if known) K230774

Device Name TEKTONA® HV US Bone Cement

Indications for Use (Describe)

TEKTONA® HV US Bone Cement is indicated for the treatment of the vertebral body using a vertebroplasty or kyphoplasty procedure. Painful vertebral compression from osteoporosis, benign lesions (hemangioma), and malignant lesions (metastatic cancers, myeloma).

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

ü 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.

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."

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K230774
Page 1 of 4

510(k) Summary

Device Trade Name:	PERLA® TL SystemTEKTONA® HV US Bone Cement
Manufacturer:	Spineart3 Chemin de Pré Fleuri1228 Plan Les OuatesGeneva, Switzerland+41 22 570 1200
Contact:	Franck PennesiChief Technical Officer+41 22 570 1200fpennesi@spineart.com
Prepared by:	MCRA, LLC803 7th Street, NW, 3rd FloorWashington, DC 20001Office: 202.552.5800
Date Prepared:	March 20, 2023
Classifications:	21 CFR 888.3027
Class:	II
Product Codes:	PMLNKBKWP
Primary Predicate:	KYPHON HV-R® Fenestrated Screw Cement, CD Horizon®Fenestrated Screw Set (K152604)
Additional Predicates:	PERLA®TL Posterior Osteosynthesis System (K213470),TEKTONA HV US Bone Cement (K122175), NEO PedicleScrew SystemTM (K212489), G21 Cement & VADER PedicleScrew System(K200596)

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Indications For Use:

PERLA® TL System

· degenerative disc disease:
spondylolisthesis;
· fracture;
dislocation;
scoliosis:
kyphosis;
spinal tumor:
· and failed previous fusion (pseudarthrosis).

TEKTONA® HV US Bone Cement

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Device Description:

The PERLA® TL System is identical to the previously cleared version, however this submission includes the additional option to use bone cement with the fenestrated screws.

Predicate Device:

Spineart submits the following information in this Premarket Notification to demonstrate that, for the purposes of FDA's regulation of medical devices, PERLA® TL System is substantially equivalent in indications, design principles, and performance to the following predicate devices, which have been determined by FDA to be substantially equivalent to pre-amendment devices:

Primary Predicate:	TEKTONA HV US Bone Cement (K122175)
Additional Predicate:	PERLA®TL Posterior Osteosynthesis SystemKYPHON HV-R® Fenestrated Screw Cement, CD Horizon®Fenestrated Screw Set (K152604)NEO Pedicle Screw System™ (K212489)G21 Cement VADER® pedicle System (K200596)

Performance Testing Summary:

Bone cement usability testing (Usability Testing, Cement Injection Time Testing, and Cement Flow, Bolus Formation, and Screw Removal from Bone Cement Testing) was conducted to validate the use of the Perla® TL System used with bone cement.

Substantial Equivalence:

The subject devices were demonstrated to be substantially equivalent to the predicates cited in the table above with respect to indications, design materials, function, manufacturing, and performance. The non-clinical tests performed by the company included bone cement usability testing and screw removal testing was conducted to validate the use of the Perla® TL System used with bone cement.

Conclusion:

The subject device and the predicate(s) devices have intended use, have similar technological characteristics, and are made of similar materials. The subject and predicate devices are packaged in similar materials and are sterilized using similar methods. The data included in

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this submission demonstrate substantial equivalence to the predicate devices listed above. PERLA® TL System is as safe, as effective, and performs as well as, or better, than the predicate devices.

Regulation Number and Section

§ 888.3027 Polymethylmethacrylate (PMMA) bone cement.

(a)
Identification. Polymethylmethacrylate (PMMA) bone cement is a device intended to be implanted that is made from methylmethacrylate, polymethylmethacrylate, esters of methacrylic acid, or copolymers containing polymethylmethacrylate and polystyrene. The device is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement.”