In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00010

Submission Number:
00010
Commenter:
Russell Cohen Hoffing
State:
California
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
I am a concerned citizen and scientist working in the field of cognitive training and am writing to ask for the reversal of this decision by FTC targeting "Carrot Neurotechnology" and in particular the vision training game "Ultimeyes". My concerns are regarding the decision that these training regimes do not improve vision. This training is based off a hundred years of research in Visual Perceptual Learning, that have been shown to improve aspects of vision. Ultimeyes, as shown in the article published in a prestigious journal Current Biology using this training, was novel in combining many of these methods and was shown to improve vision as measured by standard visual tests. In these training paradigms, a double-blind procedure is not needed to show efficacy. As double-blind procedures can prove to be quite difficult in these studies, active control and crossover groups have been used to determine efficacy. These practices are widely accepted by the scientific community and should be acceptable standards. Furthermore, basic research as funded by Governmental agencies including NIH are increasingly looking for investigators to translate knowledge into benefits for the public. ULTIMEYES was created with funding from this governmental agencies to do just that. This a training regime that translates basic visual perceptual learning techniques into a form that is accessible, possibly beneficial and most importantly minimally invasive. Furthermore, these types of endeavors by scientists to push the translation of basic science promotes the welfare and potential benefit to the public. Being involved with companies that then use this training regimes further promotes the scientific community to develop and research techniques that improve the quality and efficacy of cognitive training. Traditionally if someone of low vision or cognitive deficiency wanted to improve these deficits, they are limited to pharmaceuticals, surgeries or in person therapies. These methods are costly and time consuming and invasive. Cognitive training HAS potential, especially vision training games like that of ULTIMEYES which has shown efficacious results in three peer reviewed journals, and furthermore is NON-INVASIVE posing little threat to consumers. In this ruling in particular targeting the developers of this vision training game discourages other scientists and businesses to invest their time and money in products that have shown efficacy and great potential, and are cheap and minimally invasive, to help the public. As a concerned citizen and scientist I ask that you reverse this decision.