In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00031

Submission Number:
Christopher Pack
Outside the United States
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
As a vision scientist, I find the FTC's decision in this matter to be completely inscrutable. The FTC has claimed that Carrot Neurotechnology did not have sufficient evidence to claim that their software could improve vision, and much seems to depend on the FTC's definition of "sufficient." In fact the idea that vision training can improve visual perception is hardly controversial in the peer-reviewed scientific literature, having been documented many times by many independent groups over the years. The notion of "sufficient" for the FTC appears to have something to do with double-blind studies, but from an outsider's perspective this seems like an arbitrary threshold, and in fact it's not clear that it makes sense scientifically. Another seemingly arbitrary aspect of the decision is the target. Carrot Neurotechnology appears to consist of little more than a website and a few volunteers working part-time. By contrast, large companies routinely market their products with magazine ads and television commercials, based on the same standards of evidence (and indeed, largely the same evidence) cited by Carrot. It may be the case that these other companies have been more careful in the specific wording of their ads, but I doubt that such a legalistic distinction would be appreciated by the average consumer. The claim is quite clearly that their products can improve cognitive performance. And of course, on a larger scale, I can walk into any pharmacy in the U.S. and find entire shelves devoted to products that have been shown empirically *not* to work -- CVS for example sells homeopathic remedies such as "Arthritis oral spray", "facial toner redness remover", "ring relief ear drops", etc. These products consist of water and nothing else. Finally, and perhaps most importantly, I can tell you that the decision to levy a substantial fine against an individual researcher has sent a chill through the scientific community. My understanding is that Dr. Seitz has not personally profited from Ultimeyes, and moreover that the amount of the fine is $150,000. This is substantially larger than the average annual salary of a professor in the University of California system, where Dr. Seitz is employed. I can find no justification for this draconian fine, neither in the FTC's press release, nor in the severity of the infraction, which apparently led to no complaints and no harmful effects. This would be comparable to fining the CEO of Exxon $40,000,000 for misstating the price of gasoline. I have little doubt that the FTC has followed its own procedures in this case. My primary concern is that the procedures, as implemented here, do not make sense as a means of protecting consumers or validating science. In this climate of uncertainty, the incentive for scientists to make their discoveries available to the public is greatly reduced. Sincerely, Christopher Pack, Ph.D. Associate Professor, Neurology & Neurosurgery Canada Research Chair, Neurophysiology of Vision (2005-2015) McGill University