In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00041

Submission Number:
Terry Boult
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
Having reviewed this case and the supporting evidence in some detail, the level of fine seems to be very aggressive. The science behind the company's claims is reasonable with detailed studies by the founders but also building on prior work of others as well as independent research validating the basic concept even if not the same exact product. While I did find the claims overstated, but the fine is inconsistent with the risk and level of over claim. The excessive fine, with no warning or attempt to have the company change their advertising/claims, may reduce potential for research to be transitioned into products, thereby stifling innovation. Also the notice is naming the owners as directly liable and thus seems to be piercing the corporate veil without any stated justification. There is no data on their treating the company funds or activities as if personal business. The unwarranted piercing of the corporate veil is an even scarier overreach as it is sending the message that an owner of a properly formed company become personally liable, destroying one of the primary benefits of incorporation. This sets an unacceptable precedence of FTC overreach.