K Number
K232648
Device Name
RODEO Telescopic Nail
Manufacturer
Date Cleared
2024-05-03

(246 days)

Product Code
Regulation Number
888.3020
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The RODEO Telescopic Nail is indicated for fractures, osteotomies, malunions and non-unions in femur and tibia in pediatric patients suffering from osteogenesis imperfecta.
Device Description
The subject RODEO™ Telescopic Nail is a self-extending rod intended to provide bone fixation. The nail includes the telescopic rod, which consists of two parts (male and female) and bone anchors, which could be either a cap or an epiphyseal screw suitable to the anatomical application. The nail is provided in sterile and non-sterile version and is available in five diameters (3.5mm, 4.0mm, 4.5mm, 5.0mm and 6.0mm), identified by the outer diameter of the female part of the rod, and five lengths for each diameter model (from 100 mm up to 350 mm). Application and removal are performed with Orthofix general orthopedic instrumentation. The subject RODEO™ Telescopic Nail consists of three different components which are intended to be assembled to form the implant: Male component - A solid shaft with a built-in bone anchor for bone connection; the bone anchor has the same design as the cap (described below). Female component - A hollow shaft designed to host the male component. Bone anchors - Two options are available depending on the desired application: Cap - A self-locking screw to be connected with the female component at the opposite aspect of the extremity relative to the male component. Epiphyseal Pin - A threaded pin to be inserted into the distal extremity hole to hold the female component in position and prevent migration (see Figure 3) When the male and female components are assembled, the resulting implant is a telescopic rod. Male and female components are free to move both axially and rotationally; this allows the nail to extend axially as the patient growth occurs while allowing rotation around the bone anchors. The subject implants are made from AISI 316LVM stainless steel, conforming to ASTM F138 and ISO 5832-1.
More Information

No
The description focuses on the mechanical design and materials of a telescopic nail for bone fixation. There is no mention of any software, algorithms, or data processing that would suggest the use of AI/ML.

Yes
The device is described as providing "bone fixation" and is used for "fractures, osteotomies, malunions and non-unions," which are therapeutic applications.

No

The device is a self-extending rod intended to provide bone fixation for fractures, osteotomies, malunions, and non-unions, which are all treatment-oriented functions rather than diagnostic ones.

No

The device description clearly outlines physical components made of stainless steel, such as rods, anchors, caps, and pins, which are implanted into the body. This indicates a hardware medical device, not a software-only one.

Based on the provided information, the RODEO Telescopic Nail is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • IVD Definition: In vitro diagnostic devices are used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information about a person's health.
  • RODEO Telescopic Nail Function: The description clearly states that the RODEO Telescopic Nail is a "self-extending rod intended to provide bone fixation." It is an implantable device used to stabilize fractures and correct bone deformities.
  • Lack of Diagnostic Activity: The device does not analyze biological samples or provide diagnostic information. Its function is purely mechanical and therapeutic.

Therefore, the RODEO Telescopic Nail falls under the category of a medical device (specifically, an orthopedic implant), but not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The RODEO Telescopic Nail is indicated for fractures, osteotomies, malunions and non-unions in femur and tibia in pediatric patients suffering from osteogenesis imperfecta.

Product codes

HSB

Device Description

The subject RODEO Telescopic Nail is a self-extending rod intended to provide bone fixation. The nail includes the telescopic rod, which consists of two parts (male and female) and bone anchors, which could be either a cap or an epiphyseal screw suitable to the anatomical application. The nail is provided in sterile and non-sterile version and is available in five diameters (3.5mm, 4.0mm, 4.5mm, 5.0mm and 6.0mm), identified by the outer diameter of the female part of the rod, and five lengths for each diameter model (from 100 mm up to 350 mm).

Application and removal are performed with Orthofix general orthopedic instrumentation.

The subject RODEO Telescopic Nail consists of three different components which are intended to be assembled to form the implant:
Male component - A solid shaft with a built-in bone anchor for bone connection; the bone anchor has the same design as the cap (described below).
Female component - A hollow shaft designed to host the male component.
Bone anchors - Two options are available depending on the desired application:
Cap - A self-locking screw to be connected with the female component at the opposite aspect of the extremity relative to the male component.
Epiphyseal Pin - A threaded pin to be inserted into the distal extremity hole to hold the female component in position and prevent migration (see Figure 3)
When the male and female components are assembled, the resulting implant is a telescopic rod. Male and female components are free to move both axially and rotationally; this allows the nail to extend axially as the patient growth occurs while allowing rotation around the bone anchors.

The subject implants are made from AISI 316LVM stainless steel, conforming to ASTM F138 and ISO 5832-1.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

femur and tibia

Indicated Patient Age Range

pediatric 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)

Mechanical testing of the subject devices to demonstrate equivalence in function and safety for the intended use of the RODEO Telescopic Nail in respect to its primary predicate Pega Medical Fassier Duval Telescopic Intramedullary System (K211292) have been performed for the following functional attributes and are included in section "Bench Testing" of this eSTAR application form, as below:
Both male and female components of the subject and predicate devices underwent mechanical testing consisting of the following as per standard ASTM F1264-16:

  • Stiffness evaluated through 4-point bending configuration
  • Yield Strength evaluated through 4-point bending configuration
  • Fatigue curve definition (1,000,000 cycles )
    End caps of the subject device were also tested by assessing welding torque resistance (the end cap is welded to the male component) and cap retention resistance (static test since the end cap is screwed onto the female component). Push-out testing (ability of cap to grip bone under axial push-out from a sawbone) was also conducted on both subject and predicate devices. Torsion properties, driving torque, pullout properties and bending of the subject epiphysial pin were compared against a reference device (quide wire, 510(k) clearance K132893) which fulfills all specification requirements called out in the operative technique of the primary predicate device.
    The performance of the nails were compared and the results are in line with the defined targets.
    Furthermore, additional static and dynamic testing was conducted on the worst case (smallest diameter) fully-assembled subject and predicate devices as per ASTM F1264-16. This same testing was also conducted on the largest diameter fully-assembled subject and predicate devices.
    As is reflected by the testing, the subject device results were equivalent or better than those of the comparable predicate device.

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

Not Found

Predicate Device(s)

K211292

Reference Device(s)

K955848, K132893, K200246

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3020 Intramedullary fixation rod.

(a)
Identification. An intramedullary fixation rod is a device intended to be implanted that consists of a rod made of alloys such as cobalt-chromium-molybdenum and stainless steel. It is inserted into the medullary (bone marrow) canal of long bones for the fixation of fractures.(b)
Classification. Class II.

0

May 3, 2024

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA) along with the Department of Health & Human Services. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text. To the left of the FDA logo is the Department of Health & Human Services logo, which consists of a stylized image of people in profile.

Orthofix SRL % Mitchell Dhority Senior Director, Regulatory Orthofix US LLC 3451 Plano Parkway Lewisville, Texas 75056

Re: K232648

Trade/Device Name: RODEO Telescopic Nail Regulation Number: 21 CFR 888.3020 Regulation Name: Intramedullary fixation rod Regulatory Class: Class II Product Code: HSB Dated: April 5, 2024 Received: April 8, 2024

Dear Mitchell Dhority:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

1

Your device is also subject to, among other requirements, the Quality System (OS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Image /page/1/Picture/6 description: The image shows a digital signature. The signature is by Farzana Sharmin -S. The date of the signature is 2024.05.03. The time of the signature is 12:06:35 -04'00'.

Farzana Sharmin, PhD Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

Submission Number (if known)

K232648

Device Name

RODEO Telescopic Nail

Indications for Use (Describe)

The RODEO Telescopic Nail is indicated for fractures, osteotomies, malunions and non-unions in femur and tibia in pediatric patients suffering from osteogenesis imperfecta.

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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3

Image /page/3/Picture/0 description: The image shows the logo for Orthofix. The logo consists of a blue abstract shape on the left, followed by the word "ORTHOFIX" in black, bold letters. A small "R" in a circle is present to the right of the "X" in "ORTHOFIX", indicating a registered trademark.

510(K) SUMMARY

ORTHOFIX SRL RODEO™ Telescopic Nail

Submitter information

Company Name:Orthofix S.r.l.
AddressVia Delle Nazioni, 9
37012 Bussolengo (VR) - Italy
Telephone+39 045 6719000
Fax+39 045 6719380
Contact PersonElvira Taccarelli
Regulatory Affairs Manager
AddressVia Delle Nazioni, 9
37012 Bussolengo (VR) - Italy
Telephone+39 045 6719000
Fax+39 045 6719380
Email addresselvirataccarelli@orthofix.it
Date prepared2024 April 5th

Trade Name, Common Name, Classification

Trade Name:RODEO™ Telescopic Nail
Common Name:Telescopic Intramedullary (IM) Nail
Classification Name:Intramedullary fixation rod
Regulation Number:21 CFR 888.3020
Product Code:HSB
Classification:Class II
Panel code:Orthopedic

Primary Predicate

Primary Predicate510(k) NumberManufacturer
Telescopic Intramedullary SystemK211292Pega Medical Fassier Duval

() Orthofix Srl | Via delle Nazioni, 9 | 37012 Bussolengo (VR) Italy \ \ +39 045 6719380 @ orthofix.com

DIREZIONE E COORDINAMENTO: Orthofix Medical Inc. (Delaware)

SEDE LEGALE: VA VITOR RSANT 6 L D SEDE SECONDARIA: VIA DELLE NAZIONI, 9 I 37012 BUSSOLENGO (VERONA) I ITALIA I Registro Imprese di Verona I R.E.A. VR 215209

4

Image /page/4/Picture/0 description: The image shows the Orthofix logo. The logo consists of a blue abstract shape on the left and the word "ORTHOFIX" in black capital letters on the right. The abstract shape is a stylized, curved design. The word "ORTHOFIX" is in a bold, sans-serif font, and there is a registered trademark symbol next to the "X".

Reference devices

Reference Devices510(k) NumberManufacturer
ORTHOFIX MODULSYSTEMK955848Orthofix s.r.l.
EDGE ORTHOPAEDICS BITE
COMPRESSION SCREWK132893Orthofix s.r.l.
JPS JuniOrtho Plating SystemK200246Orthofix s.r.l.

| Device description | The subject RODEOT™ Telescopic Nail is a self-extending rod intended
to provide bone fixation.
The nail includes the telescopic rod, which consists of two parts (male
and female) and bone anchors, which could be either a cap or an
epiphyseal screw suitable to the anatomical application. The nail is
provided in sterile and non-sterile version and is available in five
diameters (3.5mm, 4.0mm, 4.5mm, 5.0mm and 6.0mm), identified by
the outer diameter of the female part of the rod, and five lengths for
each diameter model (from 100 mm up to 350 mm).

Application and removal are performed with Orthofix general
orthopedic instrumentation.

The subject RODEOTM Telescopic Nail consists of three different
components which are intended to be assembled to form the implant:
Male component - A solid shaft with a built-in bone anchor for
bone connection; the bone anchor has the same design as the
cap (described below).Female component - A hollow shaft designed to host the male
component.Bone anchors - Two options are available depending on the
desired application:
Cap - A self-locking screw to be connected with the female
component at the opposite aspect of the extremity relative
to the male component.Epiphyseal Pin - A threaded pin to be inserted into the
distal extremity hole to hold the female component in
position and prevent migration (see Figure 3)
When the male and female components are assembled, the resulting
implant is a telescopic rod. Male and female components are free to
move both axially and rotationally; this allows the nail to extend axially
as the patient growth occurs while allowing rotation around the bone
anchors.

The subject implants are made from AISI 316LVM stainless steel,
conforming to ASTM F138 and ISO 5832-1. |
|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for use | The RODEO Telescopic Nail is indicated for fractures, osteotomies,
malunions and non-unions in femur and tibia in pediatric patients
suffering from osteogenesis imperfecta. |

() Orthofix Srl | Via delle Nazioni, 9 | 37012 Bussolengo (VR) Italy \ \ +39 045 6719380   冊 orthofix.com

DIREZIONE E COORDINAMENTO: Orthofix Medical Inc. (Delaware)

5

Image /page/5/Picture/0 description: The image shows the logo for Orthofix. The logo consists of a blue, abstract shape on the left, followed by the word "ORTHOFIX" in black, sans-serif font. A registered trademark symbol is present to the right of the word "ORTHOFIX".

| Technological
Characteristics
The following table provides a comparison and assessment of
fundamental scientific principles and technological characteristics of
the subject and the primary predicate devices. Any differences have
been demonstrated to not raise different questions of safety or
performance by virtue of objective evidence (e.g., bench testing, etc.).
Therefore, the technological characteristics of the subject RODEO
Telescopic Nail are equivalent to the primary predicate Pega

Medical Fassier Duval Telescopic Intramedullary System (K211292).
Technological
CharacteristicsSubject Device
RODEO Telescopic NailPrimary Predicate Device
Pega Medical Fassier Duval
Telescopic Intramedullary
System
1.Indications for useThis implant is indicated for
fractures, osteotomies,
malunions and non-unions in
femur and tibia in pediatric
patients suffering from
osteogenesis imperfectaThis implant is indicated as a
temporary implant to aid in
the healing of long diaphysis
fractures, osteotomies,
malunions and non-unions
and to prevent further
fractures in femur, tibia and
humerus in pediatric patients
suffering from Osteogenesis
Imperfecta without disrupting
the bone growth plate. It can
be used in procedures such
as bone lengthening
/shortening concomitantly with external
fixators in pediatric or small
stature patients with limb
length discrepancy
Assessment: The subject indications are included in the primary predicate indications
for use. The difference in the anatomical site application, more extensive for the
predicate device, do not constitute a new intended use. Equivalent - no different
questions of safety and effectiveness have been raised.
2.Anatomical SitesLong bones
(Femur, tibia)Long bones
(Femur, tibia, humerus)
Assessment: The anatomical sites for use for the subject device are within the
anatomical sites cleared for the predicate device (femur, tibia). Equivalent - no
different questions of safety and effectiveness have been raised.
3.Nail MaterialStainless Steel
(316LVM, ISO 5832-1 and
ASTM F 138)Stainless Steel
(316L, ASTM F138)
Assessment: The material for the subject implants and predicate implants is the same
(stainless steel), conforming to the same standard. 316LVM for the subject device
undergoes a vacuum melt process for further purification. Equivalent - no different
questions of safety and effectiveness have been raised.
4.General DesignMale component slides within
mating female component as
patient growsMale component slides within
mating female component as
patient grows
Assessment: The general design of the subject telescopic nail is in accordance with
standard ASTM F1264-16, and is the same of the predicate device. Equivalent - no
different questions of safety and effectiveness have been raised.
5.Bone FixationProximal and distal screw-like
anchor fixation features on
male/female components;
fixation with bi-cortical
threaded cross pin to reduce
potential nail migrationProximal and distal screw-like
anchor fixation features on
male/female components;
distal fixation option with bi-
cortical k-wire to reduce
potential nail migration
Assessment: The bone fixation method for the subject device (bi-cortical fixation with
Orthofix pins) is similar to the predicate device (bi-cortical k-wire). The change in
fixation features have been evaluated through bench testing. Equivalent - no different
questions of safety and effectiveness have been raised.
6.Nail Diameters3.5, 4.0, 4.5, 5.0 and 6.0 mm (5
diameters)3.2, 4.0, 4.8, 5.6 and 6.4 mm
(5 diameters)
Assessment: Size ranges of subject are similar to primary predicate device. Potential
performance differences arising from variations in size offerings have been
demonstrated through bench testing to not raise significant new questions. The subject
device diameters are within the cleared range of the predicate device.
Equivalent - no different questions of safety and effectiveness have been raised.
7.Nail LengthsUp to 350mmUp to 420 mm
Assessment: Nail lengths of subject are similar to primary predicate device. The subject
device nail lengths are within the cleared range of the predicate device.
Equivalent - no different questions of safety and effectiveness have been raised.
8.Single Use
Yes
Yes
Assessment: Subject device single use status is identical to predicate device.
Equivalent - no different questions of safety and effectiveness have been raised.
9.Sterility Status
Sterile and Non-sterile
Sterile and Non-sterile
Assessment: Subject device sterility status is identical to predicate device.
Equivalent - no different questions of safety and effectiveness have been raised.
10.Sterilization MethodRadiation
Radiation
Assessment: Subject device sterilization method is identical to predicate device.
Equivalent - no different questions of safety and effectiveness have been raised.

DIREZIONE E COORDINAMENTO: Orthofix Medical Inc. (Delaware)

6

Image /page/6/Picture/0 description: The image shows the logo for Orthofix. The logo consists of a blue, abstract shape on the left, followed by the word "ORTHOFIX" in black, bold letters. A small "R" in a circle, indicating a registered trademark, is located to the upper right of the "X" in "ORTHOFIX".

DIREZIONE E COORDINAMENTO: Orthofix Medical Inc. (Delaware)

SED LEGAL: VA VITOR PAAN I L L. P. P. (REZORE COORDINALITO, P. P. (R.) Mecial Inc. Patrial Mercial Mercer Mineral Mercer Mineral Merce (Meral P.E.A. M 12776) Cap Soc. Eu. 1.

7

Image /page/7/Picture/1 description: The image shows the Orthofix logo. The logo consists of a blue abstract shape on the left and the word "ORTHOFIX" in black letters on the right. The abstract shape is a curved shape that resembles a stylized "O". The word "ORTHOFIX" is in a bold, sans-serif font. There is a registered trademark symbol to the right of the word "ORTHOFIX".

| Performance
Analysis | Mechanical testing of the subject devices to demonstrate equivalence
in function and safety for the intended use of the RODEO Telescopic
Nail in respect to its primary predicate Pega Medical Fassier Duval
Telescopic Intramedullary System (K211292) have been performed for
the following functional attributes and are included in section "Bench
Testing" of this eSTAR application form, as below:
Both male and female components of the subject and predicate devices
underwent mechanical testing consisting of the following as per
standard ASTM F1264-16:

  • Stiffness evaluated through 4-point bending configuration
  • Yield Strength evaluated through 4-point bending configuration
  • Fatigue curve definition (1,000,000 cycles )
    End caps of the subject device were also tested by assessing welding
    torque resistance (the end cap is welded to the male component) and
    cap retention resistance (static test since the end cap is screwed onto
    the female component). Push-out testing (ability of cap to grip bone
    under axial push-out from a sawbone) was also conducted on both
    subject and predicate devices. Torsion properties, driving torque,
    pullout properties and bending of the subject epiphysial pin were
    compared against a reference device (quide wire, 510(k) clearance
    K132893) which fulfills all specification requirements called out in the
    operative technique of the primary predicate device.
    The performance of the nails were compared and the results are in line
    with the defined targets.
    Furthermore, additional static and dynamic testing was conducted on
    the worst case (smallest diameter) fully-assembled subject and
    predicate devices as per ASTM F1264-16. This same testing was also
    conducted on the largest diameter fully-assembled subject and
    predicate devices.
    As is reflected by the testing, the subject device results were equivalent
    or better than those of the comparable predicate device. |
    |-------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
    | Conclusion | Based upon equivalences in: intended use, operating principles, and
    the non-clinical performance data, the subject RODEO Telescopic Nail
    has been shown to be substantially equivalent to the legally marketed
    predicate device. |

() Orthofix Srl | Via delle Nazioni, 9 | 37012 Bussolengo (VR) Italy ↑ 2 +39 045 6719380   冊 orthofix.com

DIREZIONE E COORDINAMENTO: Orthofix Medical Inc. (Delaware)

SED LEGAL: VA VITOR PAAN I L L. P. P. (REZORE COORDINALITO, P. P. (R.) Mecial Inc. Patrial Mercial Mercer Mineral Mercer Mineral Merce (Meral P.E.A. M 12776) Cap Soc. Eu. 1.