In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00015

Submission Number:
00015
Commenter:
Rosemary Cowell
State:
Massachusetts
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
We believe this ruling is wrong-headed and grossly unjust. The peer-reviewed scientific publications that stem from the laboratory of Dr. Aaron Seitz, as well as from the laboratories of other researchers, provide relatively convincing evidence that perceptual learning can improve vision. We would dispute the claim (implicit) in paragraph 12 of the Complaint, that the scientific evidence that Ultimeyes can improve vision constitutes an inadequate foundation for making this claim in the marketing materials. We note, also, that the commissioners ought to re-educate themselves in the scientific method. The opening phrase of paragraph 12 implies that the Commission expects 'proof' of a hypothesis before marketing claims are made. No piece of evidence stemming from any empirical test of any hypothesis can 'prove' a hypothesis to be correct. All the scientific method can do is find evidence, or fail to find evidence, in favor of a hypothesis. It can tip the scale toward or away from acceptance of a hypothesis as being likely to be correct. The empirical method simply gives us improved certainty over whether an idea is a reasonable approximation to reality. Scientists never use the word 'proof' in scientific documents. So, by the implied standard that a product should be proven to work before it can be advertised as working, then no claims should ever be made about the efficacy of any commercial product for achieving any result whatsoever, double-blind trial or no. In line with the fact that the Chief Scientist of Ultimeyes is a respected scientist, we did not notice any statement that science has 'proven' the app to improve vision in the quoted marketing language used by Ultimeyes. The marketing materials appear to have used language entirely commensurate with the empirical evidence gathered. Rosemary Cowell, PhD Assistant Professor Department of Psychological and Brain Sciences University of Massachusetts, Amherst David Huber, PhD Professor Department of Psychological and Brain Sciences University of Massachusetts, Amherst