The Tempus™ Cervical Plate System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion.
Device Story
Tempus™ Cervical Plate System is a spinal fixation orthosis consisting of titanium alloy plates and bone screws. Used by surgeons in clinical settings to stabilize the cervical spine (C2-T1) during fusion procedures. Plates are available in various lengths for one to five-level fusions; screws are available in multiple diameter-length combinations. Device features preassembled locking pins that cover screw heads to prevent back-out. Surgeon inserts screws through plate openings into vertebral bodies; locking pins are then engaged to secure the construct. Provides mechanical stabilization to the cervical spine, facilitating fusion and potentially alleviating symptoms associated with DDD, trauma, or spinal deformities.
Clinical Evidence
No clinical data. Bench testing only. The device underwent static axial compression bending, static torsion, and dynamic axial compression bending in accordance with ASTM F1717-11 (Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model). Results confirmed the construct withstands anticipated forces comparable to legally marketed predicate devices.
Technological Characteristics
Materials: Titanium-6 Aluminum-4 Vanadium ELI alloy (ASTM F136). Design: Plates with preassembled locking pins for screw head retention. Energy source: None (mechanical). Connectivity: None. Sterilization: Not specified. Form factor: Multi-level cervical plates and bone screws.
Indications for Use
Indicated for anterior cervical fixation (C2-T1) in patients with degenerative disc disease, spondylolisthesis, trauma (fracture/dislocation), spinal stenosis, deformities (scoliosis, kyphosis, lordosis), tumor, pseudoarthrosis, or failed previous fusion.
Regulatory Classification
Identification
A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.
Centerpulse Spine-Tech Trinica Select™ Anterior Cervical Plate System (K012305)
Submission Summary (Full Text)
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# 5.510(K) Summary
| Submitter's Name: | NeuroStructures, LLC |
|----------------------------|-----------------------------------------------------------------------------------------------------------------------------|
| Submitter's Address: | 63 Bovet Road, Suite 135<br>San Mateo, CA 94402 |
| Submitter's Telephone: | 800-352-6103 |
| Contact Name: | John Stephani |
| Date Summary was Prepared: | 02/16/2012 |
| Trade or Proprietary Name: | Tempus™ Cervical Plate System |
| Common or Usual Name: | Spinal intervertebral body fixation orthosis |
| Classification: | Class II per 21 CFR §888.3060 |
| Product Code: | KWQ |
| Classification Panel: | Orthopedic and Rehabilitation Devices Panel |
| Predicate Devices: | Synthes CSLP Cervical Plate (K030866)<br>Centerpulse Spine-Tech Trinica Select™ Anterior Cervical Plate<br>System (K012305) |
### Description of the Device Subject to Premarket Notification:
The Tempus™ Cervical Plate System consists of screws and plates. Screws are available in a variety of diameter-length combinations. Plates are available in a variety of lengths to accommodate fusion procedures from one to five levels of the cervical spine. Fixation is achieved by inserting bone screws through the openings in the plate into the vertebral bodies of the cervical spine. The Tempus™ Plates include locking pins that cover the heads of the bone screws to reduce the potential for screw back-out. The locking pins come preassembled to the plate.
#### Indications for Use
The Tempus™ Cervical Plate System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion.
The indication for use for the Tempus™ Cervical Plate System is similar to that of the Centerpulse Spine-Tech Trinica Select™ Anterior Cervical Plate System (K012305) and similar to that of Synthes Spine Anterior CSLP System (K030866). The Synthes device does not include deformity in the indications for use but is similar in all other aspects. As the subject device has indications that are identical to one of
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the predicate devices and similar to the second predicate device device does not introduce differences that are critical to the surgical use of the device.
#### TECHNICAL CHARACTERISTICS
The plates and screws are manufactured from titanium alloy meeting requirements of ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Allov for Surgical Implant Applications (UNS R56401). Titanium alloy has a successful history of use in the spinal implant industry and use of it in these devices does not introduce any previously unaccepted patient risks. The Synthes CSLP plate is manufactured from commercially pure titanium, but the Trinica plate and Tempus™ plate are both manufactured from titanium alloy.
The Tempus™ Plates include locking pins that cover the bone screws to reduce the potential for screw back-out. The locking pins come preassembled to the plate. Both of the predicate devices have an interference to the screw head with the same intent. The Synthes CSLP plate has an automatic locking mechanism that collapses over the head of the screw. The Trinica™ Plate has a manual locking cover that is engaged over the screw head after the place, similar in technical characteristics to the locking pin that is utilized in the Tempus™ plate.
#### PERFORMANCE DATA
The Tempus™ Cervical Plate System has been tested in static axial compression bending, static torsion, and dynamic axial compression bending in accordance with ASTM F1717–11 Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model. The results of this non-clinical testing show that the Tempus™ Cervical Plate System can withstand the anticipated forces of the cervical spine and legally marketed predicate devices.
#### CONCLUSION
The overall technology characteristics and mechanical performance data lead to the conclusion that the Tempus™ Cervical Plate System is substantially equivalent to the predicate devices.
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which features three diagonal lines that curve and merge into a single line at the bottom. The logo is surrounded by text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" in a circular arrangement.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
NeuroStructures, LLC % Meredith May, MS Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918
MAY 2 3 2012
Re: K120515
Trade/Device Name: Tempus Cervical Plate System Regulation Number: 21 CFR 888.3060 · Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: K WQ Dated: February 16, 2012 Received: February 29, 2012
Dear Ms. May:
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 for too stated on the 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 . r ou may, aterest 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 addition. Trease nover, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be may oc subject to additions, Title 21, Parts 800 to 898. In addition, FDA may round in further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean r rease oc advised that i Dri 3 ibsunted or a or device complies with other requirements of the Act that I Dr Has that to and regulations administered by other Federal agencies. You must of any I ederal statutes and regaranents, including, but not limited to: registration and listing (21
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Page 2 – Ms. Meredith May
CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical Cr K F at 807), labeling (21 OFR 803); good manufacturing practice requirements as set device-related duverse ovents) (21 CFR Part 820); and if applicable, the electronic forth in the quality systems (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 800), please If you dcsire specific advice to: your do real conters offices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Aso, please the Center 10. Doviete and readers of the sees of premarket notification" (21CFR Part note the regulations 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 rou may obtain of Scherers, 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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
for Ront mair
LLC
Mark N. Melkerson ల్ల Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## 4. Indications for Use Statement
#### Device Name: Tempus™ Cervical Plate System
The Tempus™ Cervical Plate System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion.
> Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
## Concurrence of CDRH, Office of Device Evaluation (ODE)
.
(Division Sign-Off) Division of Surgical, Orthopedic, nd Restorative Devices
510(k) Number___K120515
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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).
2. The results table
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.
4. Device detail page: chat and citations
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Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
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.