In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00069

Submission Number:
Daniel Polley
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
There is an extensive literature describing neurochemical, neurophysiological and even microstructural changes in sensory and motor areas of the adult neocortex with training. There is every reason to believe that properly designed sensory and motor training interfaces can bring about lasting, generalized improvements in perception and motor control. This is a relatively new area for commercial development and the the spirit and intellectual drive behind legitimate, well-intentioned companies like Carrot Neurotechnologies should be encouraged. This area of game development is wholly separate from applications that purport to improve working memory, reverse cognitive decline and the like, for which there is far less scientific support. The FTC needs to develop a well reasoned, transparent policy for this new commercial space. Consideration should be given to consider the burden of proof for training technologies. Is a double blind placebo controlled randomized study even reasonable for this type of intervention? What is a sugar pill placebo control for a game? It's unfair to mark Carrot Neurotechnologies with the scarlet letter when the entire field is operating in a murky policy area and other companies have made more bombastic claims. Dr. Seitz is not the villain in this case; the FTC penalty is disproportionate to the offense and will stifle innovation in this important, developing field for which conventional therapies are lacking.