In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00006

Submission Number:
00006
Commenter:
Michael Merzenich
State:
California
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
Your actions against Carrot Technology and Dr. Aaron Seitz is, in my view, heavy-handed, and unjustifiably destructive. In his product development approach, Dr. Seitz and colleagues applied long-established progressive training strategies to drive individually-demonstrable improvements in individual performance abilities in the customers who used their app. Their training strategy has been applied thousands of times in controlled trials in perceptual psychophysics, and changes in behavior and in the physical brain resulting from training in this form has been documented in animal and human studies many thousands of times. Performance gains were recorded in all but a handful of those studies. Moreover, from a collection of several hundred thousand animal and human studies, we now know that performance improvement is a direct product of positive, progressive brain change. That's where it comes from. In Dr. Seitz's case, one could cite more specific studies in which individuals were trained using strategies that closely paralleled those applied in the Carrot app. Those include many random-assignment controlled trials. Why take such a strong position about this, when a massive body of evidence supports the scientific validity of what Dr. Seitz was trying to achieve--for human benefit--in Carrot Technologies? There are thousands of better targets more deserving of your regulatory review in the brain health field, where scientific support is more often than not paper thin, and commercial claims are almost completely unsupported by certain evidence. By contrast, Dr. Seitz's efforts arise from a literal mountain of evidence from the relatively straightforward neuroscience of perceptual learning and brain plasticity. As a member of the National Academy of Sciences and the National Academy of Medicine who has spent 50 years studying this science, I am an informed expert about the strategies deployed in Dr. Seitz's, and in the science that supports it. Please contact me if you would like to discuss these issues with me in more depth.