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510(k) Data Aggregation

    K Number
    K251862
    Manufacturer
    Date Cleared
    2025-08-11

    (55 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The External Fixation Bone Distractor is intended for treatment of non-union or pseudoarthrosis of long bones and correction of bony or soft tissue defects or deformities.
    The External Fixation Bone Distractor is indicated for adult and pediatric (greater than 2 through 21 years of age) patients.

    Device Description

    The Paragon 28 External fixation Bone Distractor is a transverse bone transport system designed to assist in the controlled movement of a bone segment across a defect. The device can be used independently or in conjunction with the Monkey Rings External Fixation System (K232838) or Monkey Bars Pin to Bar External Fixation System (K242452) to form hybrid frames.

    AI/ML Overview

    The provided FDA 510(k) clearance letter for the "External Fixation Bone Distractor" does NOT include information about acceptance criteria or a study that proves the device meets specific performance criteria through clinical data, especially not in the context of an AI/ML-driven medical device.

    This document describes a traditional medical device (an external fixation system) and its clearance is based on substantial equivalence to existing predicate devices, rather than on meeting specific performance metrics derived from a study like an MRMC or standalone AI performance evaluation. The "Performance Testing" section explicitly states: "No additional bench testing was performed for the subject device. Instead, a worst-case analysis was conducted using existing data from other components within the device system." This means the clearance is based on engineering design analysis and comparison to mechanically similar, already cleared components, not on a study with clinical performance acceptance criteria.

    Therefore, I cannot extract the requested information from the provided text. The questions posed relate to the evaluation of AI/ML-driven medical devices, which operate under different regulatory and performance evaluation paradigms.

    To answer your request thoroughly, I will indicate that the information is not present in the provided document for each point.


    Here's the breakdown, indicating the information is not present based on the provided FDA 510(k) letter:

    1. A table of acceptance criteria and the reported device performance

    • Information Not Present: The document does not specify quantitative acceptance criteria for clinical performance (e.g., sensitivity, specificity, accuracy) nor does it report performance metrics from a clinical study. The clearance is based on substantial equivalence and mechanical properties derived from "worst-case analysis" using existing data, not a specific performance study against defined clinical criteria.

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Information Not Present: No test set is mentioned, as there was no clinical performance study conducted or reported for this 510(k) submission. The document relies on existing data from other components and worst-case analysis for mechanical performance.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Information Not Present: This is not applicable. There was no test set with clinical ground truth established by experts.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Information Not Present: This is not applicable. No test set involving human expert adjudication was used.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • Information Not Present: An MRMC study was not done. The device is a mechanical medical device, not an AI/ML-driven diagnostic or assistive tool.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Information Not Present: A standalone performance study was not done. The device is a mechanical bone distractor, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Information Not Present: Ground truth, in the context of clinical performance evaluation for AI/ML devices, is not relevant here as it's a mechanical device. The "ground truth" for this device's clearance relates to its mechanical integrity and biocompatibility, established through engineering standards (ASTM F1541-17) and material properties.

    8. The sample size for the training set

    • Information Not Present: A training set is not applicable. This is a mechanical device, not an AI/ML system.

    9. How the ground truth for the training set was established

    • Information Not Present: This is not applicable. No training set or associated ground truth establishment method is mentioned.
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    K Number
    K250952
    Manufacturer
    Date Cleared
    2025-07-18

    (112 days)

    Product Code
    Regulation Number
    N/A
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28 Inc

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Baby Gorilla®/Gorilla® Bone Plates and Bone Screws of the Baby Gorilla®/Gorilla® Plating System are indicated for use in stabilization and fixation of fractures or osteotomies; intra and extra articular fractures, joint depression, and multi-fragmentary fractures; revision procedures, joint fusion and reconstruction of small bones of the toes, feet and ankles including the distal tibia, talus, and calcaneus, as well as the fingers, hands, and wrists. The system can be used in both adult and pediatric patients. Specific examples include:

    Forefoot:

    • Arthrodesis of the first metatarsalcuneiform joint (Lapidus Fusion)
    • Metatarsal or phalangeal fractures and osteotomies
    • Lesser metatarsal shortening osteotomies (e.g. Weil)
    • Fifth metatarsal fractures (e.g. Jones Fracture)

    Mid/Hindfoot:

    • LisFranc Arthrodesis and/or Stabilization
    • 1st (Lapidus), 2nd, 3rd, 4th, and 5th Tarsometatarsal (TMT) Fusions
    • Intercuneiform Fusions
    • Navicular-Cuneiform (NC) Fusion
    • Talo-Navicular (TN) Fusion
    • Calcaneo-Cuboid (CC) Fusion
    • Subtalar Fusion
    • Medial Column Fusion
    • Cuneiform Fracture
    • Cuboid Fracture
    • Navicular Fracture

    Ankle:

    • Lateral Malleolar Fractures
    • Syndesmosis Injuries
    • Medial Malleolar Fractures and Osteotomies
    • Bi-Malleolar Fractures
    • Tri-Malleolar Fractures
    • Posterior Malleolar Fractures
    • Distal Anterior Tibia Fractures
    • Vertical Shear Fractures of the Medial Malleolus
    • Pilon Fractures
    • Distal Tibia Shaft Fractures
    • Distal Fibula Shaft Fractures
    • Distal Tibia Periarticular Fractures
    • Medial Malleolar Avulsion Fractures
    • Lateral Malleolar Avulsion Fractures
    • Tibiotalocalcaneal Joint Arthrodesis
    • Tibiotalar Joint Arthrodesis
    • Tibiocalcaneal Arthrodesis
    • Supramalleolar Osteotomy
    • Fibular Osteotomy

    First metatarsal osteotomies for hallux valgus correction including:

    • Opening base wedge osteotomy
    • Closing base wedge osteotomy
    • Crescentic Osteotomy
    • Proximal Osteotomy (Chevron and Rotational Oblique)
    • Distal Osteotomy (Chevron/Austin)

    Arthrodesis of the first metatarsophalangeal joint (MTP) including:

    • Primary MTP Fusion due to hallux ridgidus and/or hallux valgus
    • Revision MTP Fusion
    • Revision of failed first MTP Arthroplasty implant

    Flatfoot:

    • Lateral Column Lengthening (Evans Osteotomy)
    • Plantar Flexion Opening Wedge Osteotomy of the Medial Cuneiform (Cotton Osteotomy)
    • Calcaneal Slide Osteotomy

    Charcot:

    • Medial column fusion (talus, navicular, cuneiform, metatarsal) for neuropathic osteoarthropathy (Charcot)
    • Lateral column fusion (calcaneus, cuboid, metatarsal) for neuropathic osteoarthropathy (Charcot)

    In addition, the non-locking, titanium screws and washers are indicated for use in bone reconstruction, osteotomy, arthrodesis, joint fusion, fracture repair and fracture fixation, appropriate for the size of the device.

    Device Description

    The Baby Gorilla/Gorilla Plating System is comprised of bone plates, threaded bone screws, and washers. Gorilla Plates are offered in "mini" and "standard" set sizes in a variety of shapes based upon the anatomical fixation required. Screws are also offered in "mini" and "standard" sets and, in addition, in locking and non-locking versions. Size-matched washers are available for use with the non-locking screws when the latter are used for fixation without the plates. Size-matched plate washers are also available for use with plate holes when there is no desire to use a screw. The Baby Gorilla/Gorilla Plating System implants are manufactured from medical grade titanium (per ASTM F67), stainless steel (per ASTM F138), and titanium alloy (per ASTM F136).

    AI/ML Overview

    The provided text is an FDA 510(k) clearance letter for the Baby Gorilla®/Gorilla® Plating System. This document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the context of an AI/ML-driven medical device.

    Therefore, many of the requested items regarding acceptance criteria, study details, expert involvement, and ground truth are not applicable to this type of document and product (a metallic bone fixation system). This clearance is based on mechanical performance and material equivalence, not diagnostic accuracy or clinical outcomes as would be relevant for an AI/ML device.

    Here's a breakdown of the relevant information from the provided document:


    1. A table of acceptance criteria and the reported device performance

    • Acceptance Criteria: The document implies that the acceptance criteria are met if the modified design does not adversely affect the original testing performance and is "substantially equivalent" to the predicate device. Specific quantitative acceptance criteria are not detailed in this clearance letter. Instead, the focus is on demonstrating that the revised device's characteristics are similar enough to an already approved device to not raise new safety or effectiveness concerns.
    • Reported Device Performance:
      • Performance: Shown not to be adversely affected by modifications.
      • Basic Design: Similar to the predicate.
      • Material: Similar to the predicate (medical grade titanium per ASTM F67, stainless steel per ASTM F138, and titanium alloy per ASTM F136).
      • Manufacturing: Similar to the predicate.
      • Sizes (dimensions): Comparable to those offered by the predicate systems.
    CategoryAcceptance CriteriaReported Device Performance
    Overall EquivalenceThe modified design and performance are not adversely affected by changes and are substantially equivalent to the predicate device, not raising new questions of safety and effectiveness."The results of the analysis demonstrated the modified designs are substantially equivalent to the predicate devices." "Differences between the Baby Gorilla®/Gorilla® Plating System implants and the predicate devices were shown not to raise new questions of safety and effectiveness." "The subject devices possess identical indications for use, materials, design, and principles of operation as the predicates."
    PerformanceNot explicitly stated as quantitative metrics, but implicitly refers to the original testing performance of the predicate device. The modified device must not be adversely affected relative to this original performance."Engineering analysis is presented to provide evidence that the original testing and subsequent performance is not adversely affected by the modifications to the subject devices."
    Basic DesignSimilar to the predicate device."The subject Baby Gorilla®/Gorilla® Plating System components possess similar technological characteristics as the predicate device... basic design."
    MaterialSimilar to the predicate device."The subject Baby Gorilla®/Gorilla® Plating System components possess similar technological characteristics as the predicate device... material." Specifically, medical grade titanium (ASTM F67), stainless steel (ASTM F138), and titanium alloy (ASTM F136).
    ManufacturingSimilar to the predicate device."The subject Baby Gorilla®/Gorilla® Plating System components possess similar technological characteristics as the predicate device... manufacturing."
    Sizes (dimensions)Comparable to those offered by the predicate systems."The subject Baby Gorilla®/Gorilla® Plating System components possess similar technological characteristics as the predicate device... sizes (dimensions are comparable to those offered by the predicate systems)."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • This information is not provided in the document. The clearance is based on engineering analysis and comparison to a predicate device, not a clinical study with a patient test set in the traditional sense.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • This information is not applicable and not provided. This is a hardware device (bone plating system), not an AI/ML diagnostic device requiring expert interpretation for ground truth.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • This information is not applicable and not provided.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • This information is not applicable and not provided. This device is a bone plating system, not an AI-assisted diagnostic tool.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • This information is not applicable and not provided. This is a hardware device.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    • The "ground truth" for this device's substantial equivalence is its physical and mechanical properties and performance, as determined through engineering analysis and comparison to a legally marketed predicate device (K203511). It's not a clinical "ground truth" derived from patient data or expert consensus.

    8. The sample size for the training set

    • This information is not applicable and not provided. As a physical medical device, there is no "training set" in the context of an AI/ML algorithm.

    9. How the ground truth for the training set was established

    • This information is not applicable and not provided.
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    K Number
    K251850
    Manufacturer
    Date Cleared
    2025-07-14

    (28 days)

    Product Code
    Regulation Number
    888.3020
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Phantom® Hindfoot TTC/TC Nail System is indicated for tibiotalocalcaneal arthrodesis (fusion) and to provide stabilization of the hindfoot and ankle including the transverse tarsal joints coupling the mid-foot to the hindfoot. Examples of specific indications include:

    • Post-traumatic or degenerative arthritis
    • Previously infected arthrosis
    • Revision of failed ankle arthrodesis
    • Revision of failed total ankle arthroplasty
    • Talar deficiency conditions such as avascular necrosis of the talus (requiring tibiocalcaneal arthrodesis)
    • Neuromuscular deformity or other neuromuscular disease with severe deformity or instability of the ankle
    • Rheumatoid arthritis
    • Osteoarthritis
    • Nonunions or pseudarthrosis of hindfoot and distal tibia
    • Trauma (severe or malunited tibial pilon fracture)
    • Charcot foot (neuroarthropathy)
    • Severe end-stage degenerative arthritis
    • Instability and skeletal defects after tumor resection
    • Pantalar arthrodesis
    • Severe foot/ankle deformity
    Device Description

    Phantom® Hindfoot TTC/TC Nail System is comprised of intramedullary nails, screws and accessory components. The subject Phantom® Hindfoot TTC Trauma Nails are offered in a variety of sizes and lengths to accommodate variations in patient anatomy. The Phantom® TTC/TC screws insert through the intramedullary nail to secure the construct. These are offered in varying lengths to accommodate the anatomical fixation required.

    AI/ML Overview

    I am sorry, but the provided text is a 510(k) clearance letter for a medical device (Phantom® Hindfoot TTC/TC Nail System) and does not contain the specific information you are requesting about acceptance criteria, study details, expert qualifications, or ground truth establishment for a diagnostic or AI-based device.

    This document is a regulatory approval notice that states the device is substantially equivalent to a previously cleared predicate device. It confirms the device's indications for use, its classification, and mentions that "engineering analysis is presented to provide evidence that the original testing and subsequent performance is not adversely affected by the modifications to the subject devices." However, it does not elaborate on:

    1. A specific table of acceptance criteria and reported device performance.
    2. Sample sizes for test sets or data provenance.
    3. Number or qualifications of experts used for ground truth.
    4. Adjudication methods.
    5. MRMC comparative effectiveness study results or effect sizes.
    6. Stand-alone algorithm performance (as this is not an AI/diagnostic device).
    7. Type of ground truth used.
    8. Training set sample size.
    9. How ground truth for the training set was established.

    The document discusses "performance testing" and "engineering analysis" to demonstrate substantial equivalence, but it does not detail these tests in the way you've outlined for a diagnostic or AI study. The "device" in question is a surgical implant system, not a diagnostic tool or an AI algorithm that would typically have the kind of performance metrics you are seeking.

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    K Number
    K250641
    Manufacturer
    Date Cleared
    2025-05-01

    (58 days)

    Product Code
    Regulation Number
    888.3110
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The APEX 3D™ Total Ankle Replacement System is indicated as a total ankle replacement in primary surgery for patients with ankle joints damaged by severe rheumatoid, post traumatic, or degenerative arthritis. Revision surgery for these patients is also indicated for patients with sufficient bone stock present. In the United States, components are intended for cemented use only.

    Device Description

    The APEX 3D Total Ankle Replacement System has been cleared under K192994. The purpose of this submission is to introduce a new diffusion bonded talar dome to the APEX 3D Total Ankle Replacement System. The APEX 3D Total Ankle Replacement System is a cemented, fixed-bearing device comprised of a tibial component, a talar component, and a UHMWPE component used for ankle joint replacement. Based on patient anatomy, a number of component sizes and design configurations can be selected for best fit.

    AI/ML Overview

    The provided document is an FDA 510(k) clearance letter for the APEX 3D Total Ankle Replacement System. This document does not describe AI/ML-driven medical devices or related acceptance criteria studies.

    The 510(k) summary explains that the submission is to introduce a new diffusion-bonded talar dome to an already cleared total ankle replacement system. The performance testing described is focused on the physical and mechanical properties of the implant materials and manufacturing processes, such as:

    • Porous Structure Characterization
    • Diffusion Bonded Tensile Strength
    • Diffusion Bonded Static Shear Strength
    • Diffusion Bonded Fatigue Shear Strength
    • Diffusion Bonded Abrasion Resistance
    • Metallurgical Analysis
    • Accelerated Corrosion Soak

    The document explicitly states: "Clinical data are not needed to support the safety and effectiveness of the subject device."

    Therefore, I cannot provide the information requested in your prompt regarding acceptance criteria and studies for an AI/ML-driven device, as this document pertains to a mechanical orthopedic implant, not an AI/ML product.

    To answer your request, I would need a different source document that details the performance study of an AI/ML-driven medical device.

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    K Number
    K242452
    Manufacturer
    Date Cleared
    2024-11-01

    (74 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Monkey Bars Pin to Bar External Fixation System is intended to be used in adult and pediatric patients (specifically, children and adolescents aged 2 through 21 years) for provisional fixation of open and/or unstable fractures in the lower and upper extremities and pelvis. It may also be used for temporary fixation of peri-articular or intra-articular fractures. Additionally, the device can be used on fractures where soft tissue injury or an infected fracture site may preclude the use of other fracture fixation treatments.

    Device Description

    The device is used for the external stabilization of bone fractures. It consists of: Carbon fiber composite bars, 11mm diameter by 150mm to 500mm lengths, titanium combination clamp, aluminum 5 & 8 hole multi-pin clamps, aluminum straight and 30 degree angled posts, stainless steel 3mm, 4mm and 5mm thread diameter pins with 5mm diameter shanks that come in blunt tip and self tapping with 125mm through 230mm overall lengths and 20mm through 65mm thread lengths, stainless steel transfixing pin with 5mm shank, 7.2mm thread diameter, and 325mm overall length, and stainless steel instruments for implantation. The pins are implanted into bone and then they are connected using the clamps, rods and posts to form a rigid construct which holds the bone fragments rigidly in place. The pins are offered in various lengths and thicknesses.

    AI/ML Overview

    The provided text describes the "Monkey Bars Pin to Bar External Fixation System" and its substantial equivalence to predicate devices, but it does not contain information about the acceptance criteria or a study proving that an AI/software device meets these criteria.

    Instead, the document is a 510(k) summary for a physical medical device (an external fixation system), and it focuses on demonstrating substantial equivalence to legally marketed predicate devices through performance testing, primarily mechanical testing, rather than a clinical study or AI/software validation.

    Therefore, I cannot provide the requested information in the format given, as the input document does not contain details about:

    1. A table of acceptance criteria and the reported device performance for an AI/software device. The "Performance Testing" section mentions "Minimal Construct Static Compression Testing" and "predetermined acceptance criteria or were otherwise considered acceptable," but it doesn't quantify these criteria or results in a table for an AI system.
    2. Sample size used for the test set and data provenance for an AI/software device.
    3. Number of experts and qualifications for establishing ground truth for an AI/software device.
    4. Adjudication method for an AI/software device.
    5. Multi-reader multi-case (MRMC) comparative effectiveness study.
    6. Standalone (algorithm-only) performance.
    7. Type of ground truth used (expert consensus, pathology, outcomes data, etc.) for an AI/software device.
    8. Sample size for the training set for an AI/software device.
    9. How the ground truth for the training set was established for an AI/software device.

    The document explicitly states: "Clinical data are not needed to support the safety and effectiveness of the subject device." This further confirms that the provided text is not about an AI/software device's clinical performance.

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    K Number
    K234128
    Manufacturer
    Date Cleared
    2024-08-22

    (238 days)

    Product Code
    Regulation Number
    888.3020
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Phantom Fibula Nail System is intended for use in the fixation of fibular fractures and osteotomies.

    Device Description

    The Phantom Fibula Nail System consists of nails, screws, and accessories for the intended use of fibula repair. The implants are provided in multiple sizes and lengths.

    AI/ML Overview

    This FDA 510(k) summary does not contain information about the acceptance criteria or a study proving the device meets those criteria in the context of an AI/ML device, as the Phantom Fibula Nail System is a physical medical device (intramedullary fixation rod) and not an AI/ML product.

    Therefore, the requested information components (1 through 9) related to AI/ML device performance, ground truth, and study design are not applicable to this document. The document describes the substantial equivalence of the physical device to a predicate device through performance testing of the device components (e.g., ASTM F1264 for nails, ASTM F543 for screws, ASTM F1875 for corrosion).

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    K Number
    K241864
    Manufacturer
    Date Cleared
    2024-07-25

    (28 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    Device Description
    AI/ML Overview
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    K Number
    K240259
    Manufacturer
    Date Cleared
    2024-06-24

    (145 days)

    Product Code
    Regulation Number
    888.3110
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The APEX 3D Total Ankle Replacement System is indicated as a total ankle replacement in primary surgery for patients with ankle joints damaged by severe rheumatoid, post-traumatic, or degenerative arthritis. Revision surgery for these patients is also indicated for patients with sufficient bone stock present. In the United States, components are intended for cemented use only.

    Device Description

    The APEX 3D Total Ankle Replacement System is a cemented, fixed-bearing device comprised of a tibial component, a talar component, and a UHMWPE component used for ankle joint replacement. Based on patient anatomy, a number of component sizes and design configurations can be selected for best fit.

    AI/ML Overview

    The provided document is a 510(k) summary for a medical device (APEX 3D Total Ankle Replacement System), which focuses on demonstrating substantial equivalence to a predicate device. It addresses the device's indications for use, description, and the performance testing conducted to assure substantial equivalence.

    However, the document does NOT contain information related to software or AI device performance, acceptance criteria, or ground truth establishment relevant to the questions asked about AI/software validation.

    Therefore, I cannot extract the requested information from the provided text. The document explicitly states:

    • "Clinical data are not needed to support the safety and effectiveness of the subject device." This indicates that there was no clinical study, including any involving AI or human readers, performed for this submission.
    • The tests listed are all non-clinical performance tests on the physical components of the ankle replacement system (e.g., fatigue, material characterization, micromotion, magnetic resonance compatibility). None of these involve software or AI performance metrics.

    To answer your request, if this were an AI/software device submission, the acceptance criteria and study details would typically involve metrics like sensitivity, specificity, AUC, human reader performance studies (MRMC), ground truth assessment by experts, sample sizes for training and testing, and adjudication methods. None of this information is present in the provided document.

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    K Number
    K241262
    Manufacturer
    Date Cleared
    2024-06-05

    (30 days)

    Product Code
    Regulation Number
    888.3030
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Baby Gorilla/Gorilla Bone Plates and Bone Screws of the Baby Gorilla/Gorilla Plating System are indicated for use in stabilization of fractures or osteotomies; intra and extra articular fractures, ioint depression, and multi-fragmentary fractures: revision procedures, joint fusion and reconstruction of small bones of the toes, feet and ankles including the distal tibia, talus, and calcaneus, as well as the fingers, hands, and wrists. The system can be used in both and pediatric patients. Specific examples include: Forefoot: Arthrodesis of the first metatarsalcuneiform joint (Lapidus Fusion), Metatarsal or phalangeal fractures and osteotomies, Lesser metatarsal shortening osteotomies (e.g. Weil), Fifth metatarsal fractures (e.g. Jones Fracture). Mid/Hindfoot: LisFranc Arthrodesis and/or Stabilization, 1st (Lapidus), 2nd, 3rd, 4th, and 5th Tarsometatarsal (TMT) Fusions, Intercuneiform Fusions, Navicular-Cuneiform (NC) Fusion, Talo-Navicular (TN) Fusion, Calcaneo-Cuboid (CC) Fusion, Subtalar Fusion, Medial Column Fusion, Cuneiform Fracture, Cuboid Fracture, Navicular Fracture. Ankle: Lateral Malleolar Fractures, Syndesmosis Injuries, Medial Malleolar Fractures and Osteotomies, Bi-Malleolar Fractures, Tri-Malleolar Fractures, Posterior Malleolar Fractures, Distal Anterior Tibia Fractures, Vertical Shear Fractures of the Medial Malleolus, Pilon Fractures, Distal Tibia Shaft Fractures, Distal Fibula Shaft Fractures, Distal Tibia Periarticular Fractures, Medial Malleolar Avulsion Fractures, Lateral Malleolar Avulsion Fractures, Tibiotalocalcaneal Joint Arthrodesis, Tibiotalar Joint Arthrodesis, Tibiocalcaneal Arthrodesis, Supramalleolar Osteotomy, Fibular Osteotomy, First metatarsal osteotomies for hallux valgus correction including: Opening base wedge osteotomy, Closing base wedge osteotomy, Crescentic Osteotomy, Proximal Osteotomy (Chevron and Rotational Oblique), Distal Osteotomy (Chevron/Austin), Arthrodesis of the first metatarsophalangeal joint (MTP) including: Primary MTP Fusion due to hallux ridgidus and/or hallux valgus, Revision MTP Fusion, Revision of failed first MTP Arthroplasty implant. Flatfoot: Lateral Column Lengthening (Evans Osteotomy), Plantar Flexion Opening Wedge Osteotomy of the Medial Cuneiform (Cotton Osteotomy), Calcaneal Slide Osteotomy. Charcot: Medial column fusion (talus, navicular, cuneiform, metatarsal) for neuropathic osteoarthropathy (Charcot), Lateral column fusion (calcaneus, cuboid, metatarsal) for neuropathic osteoarthropathy (Charcot). In addition, the non-locking, titanium screws and washers are indicated for use in bone reconstruction, osteotomy, arthrodesis, joint fusion, fracture fixation, appropriate for the size of the device. The Monster Screw System is indicated for use in bone reconstruction, osteotomy, arthrodesis, joint fusion, ligament fixation, fracture repair and fracture fixation, appropriate for the device. Specific examples include: Fractures and Osteotomies: Fractures of the tarsals, metatarsals and other fractures of the foot (i.e. LisFranc), Avulsion fractures and fractures of the 5th metatarsal (i.e. Jones Fracture), Talar fractures, Ankle fractures, Navicular fractures, Fractures of the fibula, malleolus, and calcaneus, Metatarsal and phalangeal osteotomies, Weil osteotomy, Calcaneal osteotomy. Hallux Valgus Correction: Fixation of osteotomies (i.e. Akin, Scarf, Chevron), Interphalangeal (IP) arthrodesis, Proximal, midshaft, or distal osteotomy, Lapidus arthrodesis. Arthrodesis/Deformity Correction: 1st MTP arthrodesis, Metatarsal deformity correction, Tarsometatarsal joint arthrodesis, Naviculocuneiform joint arthrodesis, Talonavicular arthrodesis, Subtalar joint arthrodesis, Triple arthrodesis, Medial column arthrodesis, Subtalar joint distraction arthrodesis, Ankle arthrodesis, Lateralizing calcaneal osteotomy, Lateral column lengthening, Hammertoe. Fusion resulting from neuropathic osteoarthropathy (Charcot) such as: Medial and lateral column, Subtalar, talonavicular, and calcaneocuboid.

    Device Description

    Baby Gorilla/ Gorilla Plating System: The Baby Gorilla/Gorilla Plating System is comprised of bone plates, threaded bone screws, and washers. Gorilla Plates are offered in “mini” and “standard” set sizes in a variety of shapes based upon the anatomical fixation required. Screws are also offered in “mini” and “standard” sets and, in addition, in locking and non-locking versions. Size-matched washers are available for use with the non-locking screws when the latter are used for fixation without the plates. Size-matched plate washers are also available for use with plate holes when there is no desire to use a screw. The Baby Gorilla/Gorilla Plating System implants are manufactured from medical grade titanium (per ASTM F67), stainless steel (per ASTM E138) and titanium alloy (per ASTM. Monster Screw System: The Monster Screw System is comprised of threaded bone screws (Ti Alloy or Stainless Steel) offered in 2.0mm to 9.5mm diameters (in 0.5mm increments). In addition, a 2.7mm diameter is also part of the system. The overall screw length ranges from 8mm (for smaller diameters) thru 200mm (for larger diameters). The screws are available in a variety of designs including fully or partially threaded, self-drilling or blunt, cannulated or solid, and headed or headless. Sized-matched washers are also available.

    AI/ML Overview

    The provided text is a 510(k) summary for medical devices (Baby Gorilla/Gorilla Plating System and Monster Screw System), which are orthopedic implants. This type of FDA submission focuses on demonstrating substantial equivalence to previously cleared devices rather than proving performance based on clinical studies or AI algorithm performance.

    Therefore, the document does not contain any information about acceptance criteria for an AI device, nor does it describe a study involving AI performance metrics, ground truth establishment, expert adjudication, or MRMC studies. The performance testing mentioned specifically refers to "Bacterial endotoxin testing, sterilization validation, and a cleaning Performance validation," which are standard tests for demonstrating the safety and effectiveness of the physical device itself (implants) and its sterility, not for evaluating an AI algorithm.

    Since the request is to describe the "acceptance criteria and the study that proves the device meets the acceptance criteria" in the context of an AI device, and the provided document is entirely about physical orthopedic implants and their substantial equivalence to predicates, I cannot fulfill the request using only the given input.

    The document implicitly states that the acceptance criteria relate to demonstrating substantial equivalence for the new sterile-packed offerings of the screws, plates, and washers to the previously cleared non-sterile or differently-packaged versions of the same devices. The study proving this is the submission itself, which likely included documentation of the manufacturing process changes (sterilization, packing) and the performance testing mentioned (endotoxin, sterilization, cleaning validation) to show that these changes do not raise new issues of safety or effectiveness.

    However, none of this relates to AI, machine learning, or image analysis, which the prompt heavily implies with terms like "AI vs without AI assistance," "standalone algorithm performance," "ground truth," and "expert concensus."

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    K Number
    K240594
    Manufacturer
    Date Cleared
    2024-03-26

    (22 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Paragon 28, Inc.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Grappler Suture Anchor R3FLEX IOL System is intended for the fixation of soft tissue to bone including:

    Elbow: Biceps Tendon Reattachment, Lateral Epicondylitis Repair, Tennis Elbow Repair

    Shoulder: Rotator Cuff Repair, Bankart Repair, SLAP Lesion Repair, Biceps Tenodesis, Acromio-Clavicular Separation Repair, Deltoid Repair, Capsular Shift or Capsulolabral Repair

    Hand/Wrist: Scapholunate Ligament Reconstruction, Ulnar or Radial Collateral Ligament Reconstruction, TFCC

    Foot/Ankle: Lateral Stabilization (Brostrom, Brostrom-Gould, Christman-Snook Repair), Ankle Ligament Repair, Medial Stabilization (Deltoid, Spring Ligament Repair), Achilles Tendon Repair, Metatarsal Ligament Repair, Syndesmosis Repair, Hallux Valgus Reconstruction, Digital Tendon Transfers, Mid-foot Reconstruction, LisFranc Repair

    Knee: Medial Collateral Ligament Repair, Lateral Collateral Ligament Repair, Posterior Oblique Ligament Repair, Iliotibial Band Tenodesis, Extra Capsular Reconstruction, Patellar Ligament and Tendon Avulsion Repair

    Hip: Capsular Repair, Acetabular Labral Repair

    The plate interacting anchors are only indicated for the above Hand/Wrist and Foot/Ankle indications.

    Device Description

    The Grappler Suture Anchor R3FLEX IOL System consists of suture anchors, suture, and the accompanying instrumentation for the intended use of soft tissue damage repair. The anchors are provided in titanium and all-suture and are connected by suture composed of UHMWPE.

    AI/ML Overview

    This document is a 510(k) premarket notification for a medical device called the Grappler Suture Anchor R3FLEX IOL System. It is a submission to the FDA (Food and Drug Administration) for clearance to market the device. The document states that the device is substantially equivalent to previously cleared predicate devices.

    Here's an analysis of the provided text in relation to your request about acceptance criteria and supporting studies:

    This document does not contain the detailed information you are requesting about acceptance criteria and study particulars for an AI/software-based medical device. This submission is for a physical medical device (suture anchors) and not an AI or software product.

    The relevant section in the document for performance testing is:

    Performance Testing:

    "Engineering analysis is presented to provide evidence that the original testing and subsequent performance is not adversely affected by the modifications to the subject devices. Specifically, an analysis was presented for Suture Abrasion and Dynamic Axial Dissociation Testing. The results of this testing demonstrate the subject device is substantially equivalent to the predicate devices. Bacterial endotoxin testing was conducted and the test results meet acceptance criteria of FDA recognized standards."

    Given the nature of the device (suture anchors), the "acceptance criteria" and "study" mentioned refer to engineering and biocompatibility tests for the physical product, not clinical performance studies or AI algorithm validation studies.

    Therefore, I cannot populate the table or answer most of your detailed questions regarding AI/software performance acceptance criteria and studies because this information is not present in the provided text, as it's not applicable to this type of device submission.

    However, I can extract what is mentioned about the performance testing:


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategoryReported Device Performance (Summary from text)
    Mechanical PerformanceEngineering analysis demonstrated that the original testing and subsequent performance were not adversely affected by device modifications. Results of Suture Abrasion and Dynamic Axial Dissociation Testing demonstrated substantial equivalence to predicate devices.
    Material BiocompatibilityBacterial endotoxin testing was conducted, and test results met acceptance criteria of FDA recognized standards.

    Regarding the other questions, the document does not provide the requested information because it pertains to a physical medical device, not an AI/software product.

    Here's why the specific questions cannot be answered from the provided text:

    • 2. Sample size used for the test set and data provenance: This is relevant for AI model testing with patient data. For a physical device, 'test set' usually refers to samples tested in an engineering lab. The document does not specify sample sizes for the Suture Abrasion, Dynamic Axial Dissociation, or Bacterial Endotoxin tests. Data provenance (country, retrospective/prospective) is not applicable or specified for these types of engineering tests.
    • 3. Number of experts used to establish the ground truth... and qualifications: Not applicable. Ground truth for a physical device's mechanical or biocompatibility performance is established by engineering standards and laboratory measurements, not expert consensus on interpretations of data.
    • 4. Adjudication method: Not applicable for engineering tests.
    • 5. Multi-reader multi-case (MRMC) comparative effectiveness study... human readers improve with AI vs without AI assistance: Not applicable. This is for AI-assisted diagnostic or interpretive devices.
    • 6. Standalone (algorithm only without human-in-the-loop performance): Not applicable, as there is no algorithm, only a physical device.
    • 7. Type of ground truth used (expert consensus, pathology, outcomes data, etc.): For this physical device, the "ground truth" would be the established engineering specifications and biological safety standards that the device must meet, verified through laboratory testing.
    • 8. Sample size for the training set: Not applicable, as there is no AI model or training set.
    • 9. How the ground truth for the training set was established: Not applicable, as there is no AI model or training set.

    In summary, the provided FDA 510(k) clearance letter and summary are for a physical medical device (suture anchors) and thus the content focuses on manufacturing, materials, and mechanical performance testing to demonstrate substantial equivalence, not on AI/software performance criteria or studies.

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