The Hip Modular Spacer, which consists of a modular head and stem, is indicated for temporary use (maximum 180 days) as an adjunct to total hip replacement (THR) in skeletally mature patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organisms. The head and stem components are inserted into the acetabular cavity and femoral medullary canal, respectively, following removal of the existing acetabular and femoral components and radical debridement. The device is intended for use in conjunction with systemic antibiotic therapy (standard treatment approach to an infection). The Hip Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.). The Knee Modular Spacer, which consists of a modular femoral, tibial insert component, is indicated for temporary use (maximum 180 days) as an adjunct to total knee replacement (TKR) in patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organism(s). The device is applied on the femoral component and on the tibial plate (tibial component) following removal of the existing implant and radical debridement. The use of the tibial insert component is optional, when a large tibial defect is present. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection). The Knee Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.). Because, of the inherent mechanical limitations of the device materials (gentamicin/polymethylmethacrylate), the device is only indicated for patients who will consistently use traditional mobility assist devices (e.g., crutches, walkers, canes) throughout the implantation period.
Device Story
Modular temporary hip and knee spacers; single-use; sterile; composed of gentamicin-loaded PMMA. Hip spacer: head and stem components. Knee spacer: femoral, tibial, and optional tibial insert components. Function: temporary joint replacement during two-stage revision for infection; provides natural range of motion and partial weight-bearing; preserves soft tissue; prevents muscular contraction. Used in clinical setting by orthopedic surgeons. Output: physical structural support for joint space. Benefit: facilitates subsequent permanent joint replacement; provides local antibiotic delivery as adjunct to systemic therapy. Max implantation: 180 days.
Clinical Evidence
No clinical data. Evidence based on bench testing: biocompatibility (ISO 10993), static testing (ISO 5833), fatigue testing (ASTM F2118, ISO 7206-4/6, ASTM F1800, ISO 14243-1), surface roughness (ISO 4287-97), head size/disassembly (ISO 7206-9), and antibiotic elution/bacterial anti-adhesivity testing.
Technological Characteristics
Materials: Gentamicin-loaded PMMA (polymethylmethacrylate) with color additives. Hip spacer includes internal stainless steel core. Modular design; sterile; single-use. Standards: ISO 10993 (biocompatibility), ISO 5833 (static), ASTM F2118 (fatigue), ISO 7206 (fatigue/disassembly), ISO 4287-97 (surface roughness).
Indications for Use
Indicated for skeletally mature patients (hip) or patients (knee) undergoing two-stage revision surgery due to septic processes where gentamicin is the appropriate antibiotic. Knee spacer requires consistent use of mobility aids (crutches, walkers, canes) due to material mechanical limitations.
Regulatory Classification
Identification
A hip joint femoral (hemi-hip) metallic cemented or uncemented prosthesis is a device intended to be implanted to replace a portion of the hip joint. This generic type of device includes prostheses that have a femoral component made of alloys, such as cobalt-chromium-molybdenum. This generic type of device includes designs which are intended to be fixed to the bone with bone cement (§ 888.3027) as well as designs which have large window-like holes in the stem of the device and which are intended for use without bone cement. However, in these latter designs, fixation of the device is not achieved by means of bone ingrowth.
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## SUMMARY OF SAFETY AND EFFECTIVENESS
### GENERAL INFORMATION 1
#### 1.1 Submitter and Owner of the 510(k)
Garventis LLC
Ronald Reagan and International Trade Center 1300 Pennsylvania Ave., NW - Suite 700 Washington, D.C. 20004
### Official Correspondent 1.2
Diane Mandell Horwitz, Ph.D., RAC Regulatory Affairs Consultant Mandell Horwitz Consultants, LLC 2995 Steven Martin Drive Fairfax. Virginia 20031
Telephone: (703) 307-2921 Fax: (703) 242-1117 E-mail: dmh(@mandellhorwitzconsulting.com
#### Date of Preparation 1.3
March 29, 2012
### NAME OF THE DEVICE 2
#### Trade/Proprietary Name 2.1
Hip Modular Spacer Knee Modular Spacer
#### Common/Usual Name 2.2
Modular temporary hip prosthesis with gentamicin Modular temporary knee prosthesis with gentamicin Bone cement, antibiotic
### 2.3 Classification Information
Classification Name:
Hip Joint Femoral (hemi-hip) Metallic Cemented or Uncemented Knee Joint Patellofemorotibial Polymer/Metal/Polymer Polymethylmethacrylate (PMMA) bone cement
{1}------------------------------------------------
Classification Regulation:21 CFR & 888.3360 21 CFR & 888,3560 21 CFR & 888.3027
Regulatory Class: Class II
Product Code:
KWL, KWY JWH MBB
Panel:
Orthopedic
#### 3 PREDICATE DEVICES
The predicate devices are the Tecres Interspace Hip and Knee devices cleared in 510(k) submissions K101356. The predicate devices are temporary spacers that have been classified under 21 CFR § 888.3360 and 888.3560, and are Class II medical devices.
#### 4 DESCRIPTION OF THE DEVICE
The Modular Spacers are sterile, single-use devices intended for temporary use (maximum 180 days) as ioint replacements. The Hip Modular Spacer is composed of two components (a head and a stem) that are intended to be used together to form a temporary hip spacer; the components are available in a range of sizes. The Knee Modular Spacer is composed of three independent components (a femoral component, a tibial component and a tibial insert component) that are intended to be used together to form a temporary knee spacer; the components are available in a range of sizes.
The devices are made of fully formed polymethylmethacrylate (PMMA), which is radioopaque, and contains gentamicin and color additives to give a green color.
The Modular Spacers provide a functional-mechanical mode of action; they provide patients a temporary implant allowing for a natural range of motion and partial weight-bearing during treatment. They are designed to preserve soft tissue to prevent further complications, such as muscular contraction, and to facilitate the subsequent joint replacement procedure.
### INDICATIONS FOR USE AND INTENDED USE ട്
The Modular Spacers have the following indications for use statements.
### Hip Modular Spacer
The Hip Modular Spacer, which consists of a modular head and stem, is indicated for temporary use (maximum 180 days) as an adjunct to total hip replacement (THR) in skeletally mature patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most uppropriate antibiotic based on the susceptibility pattern of the infecting micro-organisms.
The head and stem components are inserted into the acetubular cavity and femoral medullary canal, respectively, following removal of the existing acetabular and femoral components and radical debridement.
{2}------------------------------------------------
The device is intended for use in conjunction with systemic antibiotic therapy (standard treatment approach to an infection).
The Hip Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implunted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.).
### Knee Modular Spacer
The Knee Modular Spacer, which consists of a modular femoral, tibial insert component, is indicated for temporary use (maximum 180 days) as an adjunct to total knee replacement (TKR) in patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organism(s).
The device is applied on the femoral component) and on the tibial plate (tibial component) following removal of the existing implant and radical debridement. The use of the tibial insert component is optional. when a large tibial defect is present. The device is intended for use in conjunction with systemic antimicrobial untibiotic therapy (standard treatment approach 10 an infection).
The Knee Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.). Because, of the inherent mechanical limitations of the device materials (gentamicin(polymethylmethacrylate), the device is only indicated for patients who will consistently use traditional mobility assist devices (e.g., crutches, walkers, canes) throughout the implantation period.
This is the same intended use as the predicate devices. The Garventis Modular Spacers and the Tecres Interspace Hip and Knee devices are intended to be used in the same surgical procedure (two-stage revision procedure) in the same target patient population, and provide the same primary function of providing patients a temporary implant to allow for a natural range of motion and partial weight bearing.
### TECHNOLOGICAL CHARACTERISTICS AND PERFORMANCE DATA 6
The Garventis Modular Spacer devices share many similar technological characteristics compared to the predicate Tecres Interspace Hip and Knee devices. The Garventis Modular Spacers and the predicate Tecres Interspace Hip and Knee share a similar size, shape and geometry, and are made from the same materials (PMMA). Each hip device also contains an inner stainless steel core for support. The Garventis Modular Spacers and the predicate Tecres Interspace Hip and Knee both incorporate gentamicin. Both devices share the same tissue contact and duration of contact. Both are provided preformed to the user, sterile, for single-use.
The design of the Hip Modular Spacer differs from the predicate device by its modular nature; it is provided as separate head and stem components, which have to be combined to achieve the final configuration of the implant. The design of the Knee Modular Spacer differs from the predicate device by its modular nature; it is provided as separate femoral and tibial components that must be coupled to achieve the final configuration of the implant. A tibial Insert is also available to be combined optionally with the Tibial component for increasing the final thickness.
{3}------------------------------------------------
The performance data presented in this 510(k) application demonstrate the substantial equivalence of the Garventis Modular Spacers to the predicate devices, and to establish that the devices are as safe and effective as the predicates.
Biocompatibility studies were conducted according to ISO 10993 to demonstrate that the device materials are safe, suitable and appropriate for their intended use.
Physical, mechanical and pharmacological testing met the acceptance criteria to demonstrate the safety and effectiveness of the Garventis Modular Spacers. Static testing (ISO 5833) and fatigue testing (ASTM F2118) were conducted of the resin; fatigue testing (ISO 7206-4, ISO 7206-6, ASTM F1800, ISO 14243-1); surface roughness testing (1SO 4287-97) of the spacer device; head size comparison and disassembly test (ISO 7206-9) of the femoral head; antibiotic elution testing and bacterial anti-adhesivity testing.
Data were presented to show the sterility of the device, the suitability and integrity of the packaging, and to support the proposed shelf life.
{4}------------------------------------------------
## DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the circle is an abstract symbol that resembles an eagle or other bird.
### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
APR - 5 2012
Garventis, LLC. % Mandell Horwitz Consultants, LLC Diane M. Horwitz, Ph.D., RAC 2995 Steven Martin Drive Fairfax, Virginia 22031
Re: K112470
Trade/Device Name: 2GC Hip Modular Spacer Regulation Number: 21 CFR 888.3360 Regulation Name: Hip joint femoral (hemi-hip) metallic cemented or uncemented prosthesis Regulatory Class: Class II Product Code: KWL, KWY, and MBB
Trade/Device Name: 2GC Knee Modular Spacer Regulation Number: 21 CFR 888.3560 Regulation Name: Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II
Product Code: JWH and MBB
Dated: March 15, 2012 Received: March 16, 2012
Dear Dr. Horwitz:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.
{5}------------------------------------------------
## Page 2 - Diane M. Horwitz, Ph.D., RAC
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
E. Keith
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{6}------------------------------------------------
## 1-02. Indications for Use Statement
510(k) Number:
K12470
Device Names:
### Hip Modular Spacer .
## INDICATIONS FOR USE STATEMENTS
The Hip Modular Spacer, which consists of a modular head and stem, is indicated for temporary use (maximum 180 days) as an adjunct to total hip replacement (THR) in skeletally mature patients undergoing a two-stage procedure due to a septic process and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organisms.
The head and stem components are inserted into the acetabular cavity and femoral medullary canal, respectively, following removal of the existing acctabular and femoral components and radical debridement. The device is intended for use in conjunction with systemic antibiotic therapy (standard treatment approach to an infection).
The Hip Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted and a permanent device implanted or another appropriate treatment performed (e.g. resection arthroplasty, fusion etc.).
Please do not write below this line - use another page if needed.
Concurrence of CDRH, Office of Device Evaluation (ODE)
and/or
Prescription Use X (Part 21 CFR 801 Subpart D) Over the Counter Use (21 CFR 801 Subpart C)
Signature
(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K112470
{7}------------------------------------------------
## 1-02. Indications for Use Statement
510(k) Number:
K112470
Device Names:
### Knee Modular Spacer
# INDICATIONS FOR USE STATEMENT
The Knee Modular Spacer, which consists of a modular femoral, tibial insert component, is indicated for temporary use (maximum 180 days) as an adjunct to total knee replacement (TKR) in patients undergoing a for telliporary ase (maxmuli 100 ae)s and where gentamicin is the most appropriate antibiotic based on the susceptibility pattern of the infecting micro-organism(s).
The device is applied on the femoral condyles (femoral component) and on the tibial plate (tibial component) following removal of the existing implant and radical debridement. The use of the tibial insert component is optional, when a large tibial defect is present. The device is intended for use in conjunction with systemic antimicrobial antibiotic therapy (standard treatment approach to an infection).
The Knee Modular Spacer is not intended for use for more than 180 days, at which time it must be explanted THE Knev Modular Dpacer is not mension of en appropriate treatment performed (e.g. resection arthroplasty, mechanical limitations of the device materials Because of the inherent fusion etc.). (gentamicin/polymethylmethacrylate), the device is only indicated for patients who will consistently use (Echiamontopor)invalyment (e.g., crutches, walkers, canes) throughout the implantation period.
Please do not write below this line - use another page if needed.
## Concurrence of CDRH, Office of Device Evaluation (ODE)
and/or
Prescription Use (Part 21 CFR 801 Subpart D) Over the Counter Use (21 CFR 801 Subpart C)
Klaus D. Bohn
(Division Sign-Off) (Division Sign-Sign-Sical, Orthopedic, Division of Restorative Devices
510(k) Number K112470
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
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Reading rule for every project: how many summaries do you read in full?
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Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.