In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00027

Submission Number:
00027
Commenter:
Steven Silverstein
State:
New Jersey
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
Dear FTC, Regarding UltimEyes (developed by Carrot Neurotechnology): I believe the imposed fine of $150,000 is overly severe. In fact, I do not believe there should be a fine at all, since the statement that the app has been 'scientifically shown' to improve vision is supported by multiple studies. In addition, studies using similar applications have observed similar results, and there is a long history of research demonstrating perceptual learning (i.e., improvement in visual functions after repeated practice of a visual task) in healthy and impaired populations. While I understand that randomized controlled trials are considered the gold standard of evidence, these are often flawed, and smaller studies can be well designed. The evidence available should be evaluated on its own merits. This is especially the case because there are other products backed by much larger companies that are currently advertised in such a way as to convince people that their brain function will improve (e.g., Lumosity) even though there is absolutely no evidence from scientific studies to support these claims. I urge you to reconsider your decision. If this is not reversed, it may have the negative effect of dissuading researchers from trying to disseminate new tools to the general population. In cases such as the one with UltimEyes, it seems the situation could have been handled by a requirement to adjust wording in the advertisements to everyone's satisfaction, and establishment of clear guidelines regarding what type of research evidence is required to make what type of claims. Regards, Steve Silverstein