In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00019

Submission Number:
00019
Commenter:
Joseph Chancellor
State:
Outside the United States
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
I got my Ph.D. from the University of California, Riverside, and Seitz is a former colleague. I have also purchased and used the software. While I broadly support the FTCs action toward keeping software makers from making unproven scientific claims, this is an over-reach, excessive, and dangerous. Placebo-controlled, double-blind, controlled scientific studies are not the only kind of research design that can provide evidence for the efficacy of a treatment (although they do constitute "strong evidence"). Other kinds of research designs, such as what Seitz has published (and others in his field) do constitute some evidence for the efficacy of an intervention and shouldn't be entirely disregarded. It would be foolish and counter-productive to disregard standard research practices in different fields simply because they don't meet the standard for pharmaceutical interventions. If Seitz was trying to be deceptive, he wouldn't bother to go through the arduous publishing process at all. The fact that he did multiple times is good evidence for his straightforward intentions. Do the hard work and convene some experts from the field in question and come up with some reasonable guidelines, publish them, and give the companies a set time to comply.