In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
I am a vision scientist whose research includes perceptual learning. As such I am quite familiar with the work of Dr. Steitz. However, I have never collaborated with him or with Carrot Neurotechnology in any way. I have recently become aware that another College of my University is interested in recruiting Dr. Steitz, but I am not involved in the relevant decision-making in any way. Therefore, I do not have any conflict of interest in this case. I do welcome FTC's regulatory presence in this field. However, I submit that FTC's actions in this particular case have been Draconian, and the fines shockingly excessive. Many of the other commentators, all reputable researchers in this field, have also noted that the criteria applied by FTC to test the validity of trade claims by Carrot Neurotechnology bear little resemblance to the standard practices used in the field. I must concur with this overall assessment. I believe it is unwise at best for FTC to effectively supplant the professional judgement of the experts in the field with its own one-size-fits-all criterion. It also appears to me that FTC has not made due allowances for the fact that this particular field of commercial endeavor is in its infancy. In case of such burgeoning fields, regulatory actions by the government can have a disproportionate impact, depending on how they are employed. I am afraid the harsh actions of FTC in this case, unless properly remedied forthwith, will have an unintended chilling effect on the field as a whole, and risk causing us as a nation to cede, over time, our current advantage in this field to competitors overseas. As a statutory matter, FTC has considerable discretion in wielding its enormous regulatory powers. It is especially important for the FTC to exercise them in a measured and cautious fashion, and to salutary ends. I therefore respectfully ask the FTC to reevaluate its actions in this case and substantially reduce the fines to bear some resemblance to the actual facts on the ground.