In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00046

Submission Number:
Keith Nehrke
New York
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
I am not a visual neuroscience expert, but I am a tenured Professor of Medicine and a seated member of NOMD study section that reviews grants for NIH. After hearing about this case, I'm simply astounded that it has progressed this far. Clearly, this is a situation that arose because different government agencies were sending out mixed signals. Just as clearly, the fine levied here is inappropriate to the offense, such as it is. A scientist who is trying to make non-invasive technology that could help people shouldn't be penalized to this degree, and I don't understand why a simple warning wouldn't suffice. My understanding of this case is that it involves an interpretation of the underlying science which appears to be disputed by many experts in the field. If the FTC imposes judgment based on what they feel to be unvalidated scientific claims, then it behooves them to provide evidence that supports their position. Otherwise they are making an arbitrary decision that may be motivated by other factors. This is particularly concerning as it impacts scientist's ability to comply with both University and NIH mandates regarding public health research and its benefit to society. There seem to be very broad implications to this decision and I urge the FTC to consult closely with the FDA and NIH prior to reaching a decision. As of now, I think that the right and left hand of the government aren't working together. A clear consensus based upon the best available evidence is required, with buy in from all parties concerned at both the federal and university levels.