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The Smith & Nephew SURESHOT ™ Targeting System is intended to be an intraoperative image guided localization system. It is a computer assisted orthopedic surgery tool to aid the surgeon with drill positioning for screws during intramedullary nail implantation. It provides information to the surgeon that is used to place surgical instruments during surgery utilizing intraoperatively obtained electromagnetic tracking data. The Smith & Nephew SURESHOT ™ Targeting System is indicated for long bone fractures treated with intramedullary nails in which the use of stereotactic surgery may be appropriate.

Subject of this premarket notification are modifications to the SURESHOT™ Targeting System to include software updates (V4.0) to include the ability to target for the TRIGEN META-TAN Nail (previously cleared in K092748), the ability for on screen rotation using the SURESHOT™ Targeter, additional languages of the graphical user interface (for international users), updates to the graphical user interface, and updates to the Launcher program

The SURESHOT™ Targeting System is a computer controlled electromagnetic tracking system. It assists the surgeon in locating and positioning screws in an intramedullary nail implant during orthopedic trauma surgery. The link between the sterile surgical area (patient) and the instrument system is provided through an electromagnetic tracking system. Electromagnetic spatial measurement systems determine the location of instruments that are embedded with sensor coils. When the sensor-embedded instrument is placed inside controlled, varying magnetic fields, voltages are induced in the sensor coils. These induced voltages are used by the measurement system to calculate a 3D virtual position of the instrument. Because the magnetic fields are of low field strength and can safely pass through human tissue, location measurement of an object is possible without the line-of-sight constraints of an optical spatial measurement system that requires a camera.

The SURESHOT™ Distal Targeting System software is intended to be used with existing Smith & Nephew platform, instruments and implants. No new instruments or implants are being cleared via this premarket notification.

The provided text describes a 510(k) premarket notification for the Smith & Nephew SURESHOT™ Distal Targeting System V4.0. This document primarily focuses on establishing substantial equivalence to previously cleared predicate devices rather than providing detailed acceptance criteria and a standalone study proving device performance against specific targets.

However, I can extract information related to software validation and verification testing, which serves as the basis for demonstrating the device works as intended.

Here's a breakdown of the information requested, based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly present a table of quantitative acceptance criteria with corresponding device performance metrics (e.g., accuracy in mm, failure rate thresholds). Instead, it states that "Software verification and validation testing was completed in line with FDA's guidance document entitled, 'General Principles of Software Validation; Final Guidance for Industry and FDA Staff,' dated January 11, 2002."

The acceptance criteria are implicitly met if the listed preclinical tests passed, demonstrating that the "software will perform as intended." The reported performance is that "there are no new issues related to the safety and effectiveness of the subject device and the software will perform as intended as compared to the predicate."

Implicit Acceptance Criteria (based on tests performed):

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

The document does not specify a "test set" in terms of subject or case count for the preclinical testing. The tests listed are functional and technical software validation tests, typically performed in a controlled environment. Clinical data was explicitly not used or needed to support the safety and effectiveness of the subject device for this 510(k) submission. Therefore, there's no data provenance in the context of clinical studies (e.g., country of origin, retrospective/prospective).

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

Not applicable. The preclinical software tests described do not involve human expert adjudication of medical images or diagnoses to establish a "ground truth." The ground truth for these tests would be the intended software behavior and calculation correctness as defined by engineering specifications.

4. Adjudication Method for the Test Set

Not applicable, as no expert adjudication for medical data is described. The "adjudication" for software testing would be the engineering team verifying that the test results match the expected outcomes.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical data was not needed to support the safety and effectiveness of the subject device." The submission relies on demonstrating substantial equivalence to a predicate device and software verification/validation.

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

The listed preclinical tests are essentially standalone algorithm/software verification, focusing on the functionality and calculations of the device's software. The device itself (SURESHOT™ Distal Targeting System) is an "intraoperative image guided localization system" and a "computer assisted orthopedic surgery tool to aid the surgeon with drill positioning," implying a human-in-the-loop during actual clinical use. However, the testing described is of the underlying software's performance (e.g., targeting calculations, GUI functionality) in a controlled environment, which can be considered standalone verification of the software components.

7. The Type of Ground Truth Used

For the software validation and verification, the "ground truth" is likely defined by:

• Design specifications: The intended behavior, outputs, and calculations as per the software design documents.
• Known correct values: For calculations (e.g., "Targeting Calculations META"), the ground truth would be precise, pre-calculated results for a given input.
• Previous versions' behavior: For regression testing, the ground truth is the expected behavior of the existing features from prior, cleared versions.

8. The Sample Size for the Training Set

Not applicable. The text describes software updates to an existing system and verification/validation testing. This is not a machine learning model, so there is no training set in the typical sense.

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

Not applicable, as there is no training set for a machine learning model described.

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Smith & Nephew IM Nail Systems Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew IM Nail Systems and their cleared Indications for Use.

Trigen Adolescent TAN Nail System and Trigen 130° TAN Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of the Smith & Nephew Trigen Adolescent TAN Nail System and the Smith & Nephew Trigen 130° TAN Nail System and their cleared indications for use. Indications for interlocking intramedullary nails include: Simple long bone fractures, Severely comminuted, spiral, large oblique and segmental fractures, Nonunions and malunions, Poly trauma and multiple fractures, Prophylactic nailing of impending pathologic fractures, Reconstruction following tumor resection and grafting, Supracondylar fractures, Bone lengthening and shortening, Fractures that occur in and between the proximal and distal third of the long bones being treated. In addition to the indications for interlocking intramedullary nails, devices that contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability are indicated for the following: Subtrochanteric fractures with lesser trochanteric involvement, Ipsilateral femoral shaft/neck fractures, Intertrochanteric fractures.

Trigen Humeral Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew Trigen System and its cleared indications for use. TRIGEN Humeral Nail System is indicated for: Proximal and/or diaphyseal fractures of the humerus, Nonunions, Malalignments, Pathological humeral fractures, Impending pathological fractures.

Trigen InterTAN Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew Trigen InterTAN Nail System and its cleared indications for use. TRIGEN InterTAN Nails are indicated for: Simple long bone fractures, Severely comminuted spiral, long oblique, and segmental shaft, Nonunions and malunions, Poly trauma and multiple fractures, Prophylactic nailing of impending pathologic fractures, Reconstruction, following tumor resection and grafting, Bone lengthening and shortening, Subtrochanteric fractures, Ipsilateral femoral shaft/neck fractures, Intertrochanteric fractures, Intracapsular fractures.

Intramedullary Nail Systems Instruments are accessory devices and are intended to be used to assist in the implantation.of Smith & Nephew Intramedullary Nail Systems and their cleared indications for use. The Short Knee Nail, REVISION Nail and Hindfoot Fusion Nail (HFN) are indicated for: Degeneration, deformity, or trauma of both the tibiotalar and talocalcaneal articulations of the hindfoot, Tibiocalcaneal arthrodesis, Combined arthrodesis of the ankle and sub-talar joints, Avascular necrosis of the ankle and sub-talar joints, Failed total ankle replacement with sub-talar intrusion, Failed ankle arthrodesis with insufficient talar body, Rheumatoid arthritis, Severe deformity secondary to untreated talipes equinovarus or neuromuscular disease, Severe pilon fractures with trauma to the subtalar joint.

SURESHOT TAN Nail Systems Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew SURESHOT TAN Nail Systems and their cleared indications for use. SURESHOT TAN Nails are indicated for: Fractures of the femur including: simple long bone fractures, severely comminuted, spiral, large oblique and segmental fractures, Non unions and malunions, Poly trauma and multiple fractures, Prophylactic nailing of impending pathologic fractures, Reconstruction, following tumor resection and grafting, Supracondylar fractures, Bone lengthening and shortening, Fixation of fractures that occur in and between the proximal third and distal fourth of the femur. In addition, SURESHOT TAN Nails contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability and are indicated for the following: Subtrochanteric fractures;, Intertrochanteric fractures;, Ipsilateral femoral shaft/neck fractures;, Intracapsular fractures.

Intramedullary Hip Screw System Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew Intramedullary Hip Screw Systems and their cleared indications for use. Intramedullary Hip Screws are indicated for: Intracapsular fractures of the femoral neck;, Trochanteric or subtrochanteric fractures;, Osteotomies for patients with diseases or deformities of the hip;, Hip arthrodesis;, Supracondylar fractures and distal femoral fractures using a supracondylar plate;, Ipsilateral femoral shaft/neck fractures;, Intertrochanteric fractures;, Femoral neck fractures;, Subcapital fractures;, Comminuted neck and shaft fractures;, Femur reconstruction following tumor resection;, Leg length discrepancies secondary to femoral inequality;, Prophylactic nailing of impending pathologic fractures.

Ender Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew Ender Nail Systems and their cleared indications for use. ENDER Nails are indicated for: Fracture of the neck, trochanteric, and subtrochanteric region of the femur;, Distal femoral fractures with a distal fragment 10cm or longer, Tibial shaft fractures, Proximal humeral fractures.

TriMax Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew TriMax Nail Systems and their cleared indications for use. Femoral/Recon antegrade nails and retrograde nails are indicated for: Shaft fractures including severely comminuted, spiral, large oblique and segmental fractures, Non-unions and malunions, Bone lengthening/shortening, Severely comminuted shaft fractures, Pathologic fractures, pseudoarthrosis, failed osteosynthesis, Closed supracondylar fractures, Prophylactic nailing of impeding pathologic fractures. Additonal indications for the femoral/recon antegrade include: Subtrochanteric fractures with lesser trochanteric involvement, Ipsilateral femoral shaft/neck fractures. Additonal indications for retrograde nails include: Severly comminuted supracondylar fractures with or without difficult intra-articular extension, Fractures that require opening the knee joint to stabilize the femoral condylar segmarnt, Fractures above total knee implants. The TriMax Nail System is intended to be removed upon fracture healing.

Indications for interlocking intramedullary nails include: Simple long bone fractures, Severely comminuted, spiral, large oblique and segmental fractures, Nonunions and malunions, Poly trauma and multiple fractures, Prophylactic nailing of impending pathologic fractures, Reconstruction following tumor resection and grafting, Supracondylar fractures, Bone lengthening and shortening, Fractures that occur in and between the proximal and distal third of the long bones being treated. In addition to the indications for interlocking intramedullary nails, devices that contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability (e.g. Femoral Antegrade Nail, Trochanteric Antegrade Nail and Femoral/Recon Antegrade Nail) are indicated for the following: Subtrochanteric fractures, Intertrochanteric fractures, Ipsilateral femoral shaft/neck fractures. In addition to the indications for interlocking intramedullary nails, devices that use a retrograde femoral surgical approach (e.g. Knee Nail, Retrograde and Supracondylar Nails) are indicated for: Comminuted supracondylar fractures with or without intra-articular extension, Fractures that require opening the knee joint to stabilize the femoral condylar segment, Fractures above total knee implants (peri-prosthetic fractures).

Knee Fusion Nail Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew Knee Fusion Nails and their cleared indications for use. Knee Fusion Nails are indicated for: Intramedullary Knee Arthrodesis.

IP-XS Compression Nail System Instruments are accessory devices and are intended to be used to assist in the implantation of the Smith & Nephew IP-XS Compression Nail System and its cleared indications for use. The IP-XS Compression Nail System is inserted into the medullary canal of long bones for the : Alignment, stabilization, and fixation of fractures caused by disease or trauma, The fixation of long bones that have been surgically prepared {osteotomy) for correction of deformity, Arthrodesis.

SLIM (Friedl) Gliding Nail Systems Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew SLIM (Fried), Gliding Nails and their cleared indications for use. The SLIM (Friedl) Gliding Nail System is an all-purpose locking nail system for ensuring primary load stability in: Petrochanteric femoral fractures, Subtrochanteric femoral fractures, Lateral femoral neck fractures. Internal fixation with the SLIM (Friedl) Gliding Nail System is indicated in all combination injuries involving the lateral femoral neck or trochanter region and femoral shaft fractures. Thanks to its biomechanical characteristics, the SLM (Friedl) Gliding Nail System is also suitable for medical femoral neck fractures with retention of the head and simple femoral shaft factures down to the distal metaphysis. Gliding nail fixation can also be used to secure pathological fractures or to provide weight-bearing stability after varus and valgus revision osteotomies of the proximal femur.

TriGen Low Profile Bone Screw Instruments are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew TriGen Low Profile Bone Screws and their cleared indications for use. The TRIGEN Low Profile Bone Screw can be used with several types of nails in Smith & Nephew's (TRIGEN) Titanium Nail System. The TRIGEN Low Profile Bone Screw therefore has the following indications: Indications for interlocking intramedullary nails include simple long bone fractures; severely comminuted, spiral, large oblique and segmental fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction following tumor resection and grafting; supracondylar fractures; bone lengthening and shortening. Interlocking intramedullary nails are indicated for fixation of fractures that occur in and between the proximal and distal third of the long bones being treated. In addition to the indications for interlocking intramedullary nails, devices that contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability (e.g. Femoral Antegrade Nail, Trochanteric Antegrade Nail and Femoral/Recon Antegrade Nail) are indicated for the following: subtrochanteric fractures, intertrochanteric fractures, and ipsilateral femoral shaft/neck fractures. In addition to the indications for interlocking intramedullary nails, devices that use a retrograde femoral surgical approach (e.g. Knee Nail, Retrograde and Supracondylar Nails) are indicated for the following: comminuted supracondylar fractures with or without intra-articular extension; fractures that require opening the knee joint to stabilize the femoral condylar segment; fractures above total knee implants (peri-prosthetic fractures). The TRIGEN InterTAN nails are indicated for fractures of the femur including: simple shaft fractures, comminuted shaft fractures, spiral shaft fractures, long oblique shaft fractures and segmental shaft fractures; subtrochanteric fractures; intertrochanteric fractures; ipsilateral femoral shaft/neck fractures; intracapsular fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction, following tumor resection and grafting; bone lengthening and shortening. SURESHOT TAN Nails are indicated for fractures of the femur including simple long bone fractures, severely comminuted, spiral, large oblique and segmental fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction, following tumor resection and grafting; supracondylar fractures; bone lengthening and shortening; and for fixation of fractures that occur in and between the proximal third and distal fourth of the femur. In addition, SURESHOT TAN Nails contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability and are indicated for the following: subtrochanteric fractures; intertrochanteric fractures; ipsilateral femoral shaft/neck fractures; and intracapsular fractures.

Subject of this Traditional 510(k) Premarket Notification are the Smith & Nephew, Inc. intramedullary (IM) Nail Systems Instruments. The subject devices are accessory devices and are intended to be used to assist in the implantation of Smith & Nephew IM Nails and their cleared Indications for Use. Smith & Nephew IM Nail Systems Instruments can be organized into instrument families which are categorized as follows: Torque/Tightening, trials, drills, extractors, impactors, replacements, alignment, other guides and gauges, and bone preparation.

The provided document is a 510(k) Premarket Notification for Intramedullary Nail Systems Instruments, which are accessory devices used to assist in the implantation of various Smith & Nephew IM Nails. This document focuses on demonstrating substantial equivalence to predicate devices rather than providing a study with specific acceptance criteria and performance metrics for a novel device. Therefore, much of the requested information regarding acceptance criteria, performance, and detailed study methodologies for an AI/CADe device cannot be extracted directly.

This document describes the equivalence of the instruments used for implantation of nails, not the nails themselves or a diagnostic AI/CADe system.

However, I can extract the information that is present and highlight what is missing based on your request.

1. Table of Acceptance Criteria and Reported Device Performance

This information is not provided in the document as it is a 510(k) for accessory instruments, relying on substantial equivalence to predicate devices rather than demonstrating performance against specific clinical acceptance criteria. The "performance" described is the instruments' ability to assist in the implantation of already cleared nails, which is assessed through comparisons of materials, manufacturing, sterilization, and body contact.

• Share the same raw materials as predicate instruments.
• Be manufactured through the same processes as predicate instruments.
• Utilize the same sterilization procedures as predicate instruments.
• Have a similar nature of body contact as predicate instruments.
• Be similar in design and function to competing IM nail instrumentation on the market. |

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 applicable as there is no test set or clinical study conducted in the context of a new diagnostic algorithm or device requiring such data. The premarket notification relies on substantial equivalence.

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 as there is no test set or ground truth to establish for this type of device (surgical instruments).

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

This information is not applicable.

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 as no MRMC study, or any study involving human readers and AI assistance, was conducted or described. The device consists of surgical instruments, not an AI/CADe system.

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

This information is not applicable as the device is surgical instrumentation, not an algorithm or AI system.

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

This information is not applicable as no ground truth is required for demonstrating substantial equivalence of surgical instruments. The equivalence is based on physical characteristics and intended use.

8. The sample size for the training set

This information is not applicable as there is no training set mentioned or relevant for this type of device.

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

This information is not applicable as there is no training set or ground truth mentioned or relevant for this type of device.

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The TRIGEN® Low Profile Bone Screw can be used with several types of nails in Smith & Nephew's (TRIGEN) Titanium Nail System. The TRIGEN® Low Profile Bone Screw therefore has the following indications:

Indications for interlocking intramedullary nails include simple long bone fractures; severely comminuted, spiral, large oblique and segmental fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction following tumor resection and grafting; supracondylar fractures; bone lengthening and shortening. Interlocking intramedullary nails are indicated for fixation of fractures that occur in and between the proximal and distal third of the long bones being treated.

In addition to the indications for intramedullary nails, devices that contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability (e.g. Femoral Antegrade Nail, Trochanteric Antegrade Nail and Femoral/Recon Antegrade Nail) are indicated for the following: subtrochanteric fractures, intertrochanteric fractures, and ipsilateral femoral shaft/neck fractures.

In addition to the indications for interlocking intramedullary nails, devices that use a retrograde femoral surgical approach (e.g. Knee Nail; Retrograde and Supracondylar Nails) are indicated for the following: comminuted supracondylar fractures with or without intra-articular extension; fractures that require opening the knee joint to stabilize the femoral condylar segment; fractures above total knee implants (peri-prosthetic fractures).

The TRIGEN® InterTAN nails are indicated for fractures of the femur including: simple shaft fractures, comminuted shaft fractures, spiral shaft fractures, long oblique shaft fractures and segmental shaft fractures; subtrochanteric fractures; intertrochanteric fractures; ipsilateral femoral shaft/neck fractures; intracapsular fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction, following tumor resection and grafting; bone lengthening and shortening.

SURESHOT® TAN Nails are indicated for fractures of the femur including simple long bone fractures, severely comminuted, spiral, large oblique and segmental fractures; nonunions and malunions; polytrauma and multiple fractures; prophylactic nailing of impending pathologic fractures; reconstruction, following tumor resection and grafting; supracondylar fractures; bone lengthening and shortening; and for fixation of fractures that occur in and between the proximal third and distal fourth of the femur.

In addition, SURESHOT TAN Nails contain holes/slots proximally to accept screws that thread into the femoral head for compression and rotational stability and are indicated for the following: subtrochanteric fractures; intertrochanteric fractures; ipsilateral femoral shaft/neck fractures; and intracapsular fractures.

The TRIGEN® Low Profile Bone Screw is intended for single use only.

Subject of this Traditional 510(k) Premarket Notification is the TRIGEN® Low Profile Bone Screw. The subject device is a modification of the bone screws included in the (TRIGEN) Titanium Intramedullary (IM) Nail System cleared by premarket notification K981529. The TRIGEN® Low Profile Bone Screw is manufactured from titanium alloy (Ti-6Al-4V), contains an internal hex drive feature in the screw head, and is available in the sizes included in Table 1 below.

Table 1: TRIGEN® Low Profile Screw Sizes

The subject device is designed to be used with the SURESHOT® TAN Nails cleared under K092748 as well as TRIGEN® titanium intramedullary nail systems designed to use 4.5 mm or 5.0 mm diameter screws.

This document describes the TRIGEN® Low Profile Bone Screw and focuses on its substantial equivalence to previously cleared devices rather than providing acceptance criteria and performance data from a study measuring specific metrics against those criteria.

Here's an analysis of the provided text in relation to your request:

1. Table of acceptance criteria and reported device performance:

The document does not explicitly state quantitative acceptance criteria (e.g., "torsional strength must be X Nm") or report specific numerical performance outcomes against such criteria for the TRIGEN® Low Profile Bone Screw.

Instead, it states that "Performance testing has been conducted to ensure the safety and effectiveness of the subject device. Static Torsional Strength, Bending Fatigue, and Axial Pullout Strength of the subject device have been evaluated. A review of the testing has demonstrated that there are no new issues related to the safety or effectiveness of the subject device." This statement implies that the device met some internal or predicate-based performance benchmarks, but the benchmarks themselves and the specific test results are not provided.

The primary "performance" mentioned is in the context of substantial equivalence to predicate devices. The comparison in Table 2 focuses on design features (material, diameter, length, head drive, thread form, cutting tip geometry) rather than quantitative performance metrics.

2. Sample size used for the test set and the data provenance:

• Sample Size: Not specified. The document only mentions "Performance testing has been conducted" without detailing the number of units tested.
• Data Provenance: The testing appears to be internal "Performance testing" conducted by Smith & Nephew, Inc. It is not indicated whether this was retrospective or prospective, or the country of origin.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

This information is not provided and is not relevant to this type of 510(k) submission, which relies on engineering performance testing and substantial equivalence, not clinical study data with expert ground truth.

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

This information is not provided and is not relevant for the type of engineering performance testing described.

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:

No MRMC comparative effectiveness study was done. This document describes a medical device, a bone screw, not an AI or imaging diagnostic device. Therefore, AI assistance and human reader improvement are not applicable.

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

No standalone performance study for an algorithm was done. This is a physical medical device, not a software algorithm.

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

For the engineering performance testing (Static Torsional Strength, Bending Fatigue, Axial Pullout Strength), the "ground truth" would be the measured physical properties and mechanical behavior of the device compared against established engineering standards or the performance of predicate devices. There is no expert consensus, pathology, or outcomes data used for this type of "ground truth."

8. The sample size for the training set:

Not applicable. This device does not use machine learning or AI that would require a "training set."

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

Not applicable. No training set was used.

In summary of what the document does provide regarding performance and equivalence:

• Performance Testing Conducted: Static Torsional Strength, Bending Fatigue, and Axial Pullout Strength.
• Conclusion of Performance Testing: "demonstrated that there are no new issues related to the safety or effectiveness of the subject device." This implies the device met the necessary performance criteria, likely by showing equivalence to predicate devices or meeting recognized standards.
• Clinical Data: "Clinical data was not needed to support the safety and effectiveness of the subject device." This reinforces that the submission relies on engineering testing and substantial equivalence.
• Substantial Equivalence: The primary focus is on demonstrating substantial equivalence to predicate devices (K981529 and K983942) based on design, indications for use, intended use, materials, and sterilization. Table 2 details the comparison of design features between the subject device and the predicate devices.

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