In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
To Whom It May Concern: I have conducted psychology and neuroscience research on how training affects perception for more than 15 years. Dr. Seitz and his colleagues have carried out careful, rigorous, well-controlled research that conforms to the highest standards in our field. The science is very strong. Accordingly, the studies are published in top-ranked peer-reviewed journals. It is in this context that I would urge the commission to consult experts in the field regarding the complaint against Carrot Neurotechnologies. The complaint suggests that companies must adhere to "standards generally accepted by experts" but also that in order to be scientifically sound, a study must be "randomized, double-blind, and adequately controlled." The latter is simply not a possibility for perceptual training paradigms. Whereas it may be possible to use the medical model of "double-blind, randomized, placebo" studies in testing supplements or pharmaceuticals, the very nature of perceptual training makes this much less of a realistic possibility. The dozens of published peer-reviewed studies that support Ultimeyes attest that the science behind it meets "standards generally accepted by experts." I strongly support the FTC's mission to protect consumers from false claims and fraudulent products. However, Carrot Neurotechnologies has made a good-faith effort to base their product on sound scientific evidence. The punitive action against them is not in line with the spirit of FTC's support for evidenced-based decisions. Perhaps most troubling of all, the example of Carrot undoubtedly will discourage scientists from translating well-established laboratory research conducted with rigor and control to products that can serve the public. This is a shame as there is real potential for inexpensive, low-risk training interventions to have a major benefit to consumers.