In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
The proposed actions in this case do not meet the standard of fair and reasonable. As the FTC governs trade, and not medicine, a lower standard of proof is appropriate than what the FDA uses. Requiring double-blind studies is not required for bicycles, for exercise machines, or for swimming goggles, all of which have potential health-related benefits despite not being medical treatments. The proposed fines are disproportionate to the alleged misdeeds, are not in line with historical actions in equivalent cases, and set a dangerously suffocating precedent for innovation. I urge against the proposed FTC actions.