In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00064

Submission Number:
Larry Baitch
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
Re: Carrot Neurotechnology, Inc., File No. 1423132 Dear FTC Colleagues, I have been involved in vision research and ophthalmic technology for over thirty years, and have spent a great part of my career studying brain processing, visual development and binocular visual disorders in infants, adults and non-human primates. I have been on the Faculty of three Departments of Ophthalmology and have served in clinical and ophthalmic manufacturing environments. In the past 12 years I have specialized in translating ophthalmic research methodologies into FDA-approved clinical application. In my opinion, Dr. Aaron Seitz of Carrot Neurotechnology has developed a unique and elegant training system for enhancing visual performance which has been validated by university-based leading researchers in the field. While the promotional tone of the Ultimeyes website is somewhat sensational in tone, I believe that the advertised technologies are sound; they are firmly grounded in research and performed within the standards of experimental design for studies of that nature. The intentions of the company's owners are sincere, and I feel strongly that the penalties being waged by the FTC are arbitrary and excessive. Because an individual's fear of vision loss is only exceeded by the fear of death, there exists a certain mystique about the eyes and vision in the public mind that surpasses nearly all other health issues. Bogus exercise therapies (the "Bates Method" comes to mind) and sham nutritional supplements have always existed, and can easily be found in great abundance on the internet today. However, the researchers and owners of Carrot Technology cannot be included among those ill-intentioned charlatans. If the FTC feels that the claims made by Ultimeyes were overstated, then certainly an advisory letter should be issued, informing Dr. Seitz of the FTC's perceived violations and the remedies for compliance. Otherwise, this action will set a dangerous precedent, discouraging the development of potentially beneficial therapeutic modalities. As the US Government and its entities such as the National Eye Institute spends millions of dollars every year funding basic and clinical eye research, those funds would be expended in vain if the fruits of that research were only left in scientific journals. Sincerely, Larry Baitch, OD, PhD, FAAO Medical Vision Technologies, LLC [REDACTED]