In the Matter of Carrot Neurotechnology, Inc., File No. 1423132 #00073

Submission Number:
00073
Commenter:
Stanley Klein
State:
California
Initiative Name:
In the Matter of Carrot Neurotechnology, Inc., File No. 1423132
Dear FTC, Let me begin by saying that I fully appreciate the job that FTC is doing regarding truth in advertising. That is super important since consumers are constantly being misled to purchase things they don't really need. The Carrot NeuroTech situation doesn't seem to fall in that problem area since there is full consensus in the perceptual and cognitive learning community that practice, especially using attention grabbing video games show general learning and that learning can transfer to other tasks. I looked at the large number of letters to FTC from the top researchers in the field. There is clear support for improvement of vision and cognition in the vision community for the techniques used by Carrot NeuroTech. It was impressive to see so many leaders in the field sending in comments. One of the FTC complaints had to do with the need for having double-blind control conditions. It has been pointed out by many letter writers that double-blind conditions aren't possible since the control conditions are nothing like the action games being played. I want to add that in a deep sense the experiments done by Prof. Seitz and others in the field have built in controls. For example, when using a C target one must report the orientation of the C so by guessing one is correct 25% of the time. And for the standard letter naming task used by Seitz, one is correct only 1/26 of the time by guessing. So there are that sort of built in controls that avoid cheating. Also calling something a "placebo effect" isn't a good criticism, since the placebo effect involves mental based changes and it has been shown that mental changes can be quite relevant to perceptual and cognitive learning. Finally, it makes no sense to me to have such a shockingly large fine. If FTC thinks some of the advertising should be toned down that could make sense. Like maybe the ads should point out that different people would get different degrees of benefit. That type of advice by FTC could make sense. But such a large fine could backfire in discouraging researchers from working on projects that can benefit many people. I am a professor at the University of California, Berkeley. I have been doing research in Vision Science for more than 40 years. In recent years I have been studying perceptual learning. Sincerely, Stanley Klein