thank you & neuromarketing update

Gary Ruskin gary@commercialalert.org
Wed, 17 Dec 2003 07:01:25 -0800


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*Commercial Alert, December 17, 2003

1. Thank you & annual subscriber survey
2. The State of the Commons report
3. Neuromarketing update: **Commercial Alert asks feds to investigate 
neuromarketing research at **Emory** **University*

*1. Thank you & annual subscriber survey

*Dear friends,
Thank you for subscribing to Commercial Alert's email newsletter.  We 
really appreciate your attention and support. 

Please take a moment to fill out our short annual subscriber survey, and 
return it to <gary@commercialalert.org 
<mailto:gary@commercialalert.org>> We'd love to have your input to 
improve our work and meet your needs as a subscriber.

* What are the strengths of our email newsletter?
* How can we improve our email newsletter?

Finally, will you become a member of Commercial Alert by making a 
contribution?   If you are already a member, will you renew your 
membership for 2004?

In 2004, Commercial Alert will stand up for you in the fight to preserve 
our culture from the rampant commercialism that is assaulting our 
health, our values, our children, our schools and our government.

Commercial Alert now has more than 2,000 members.  This is good news.  
Our goal is to double our membership in 2004.  We can increase our 
political strength if you join Commercial Alert today or renew your 
membership.  All you need to do is to give $15, $35, $50, $100 or more.  
Contribure today at https://secure.groundspring.org/dn/index.php?id=1236 
or send your check to Commercial Alert; 4110 SE Hawthorne Blvd. #123; 
Portland, OR 97214.  Thank you in advance for your generosity.

Happy holidays.

Sincerely,

Gary Ruskin
Executive Director
Commercial Alert

*2. The State of the Commons report
*Our friends at the Friends of the Commons have produced a splendid 
report titled "The State of the Commons."  It's the best short 
introduction yet to what the commons is, why it's important, how to 
preserve it, how much it's worth, who's stealing it from us, and how we 
can get it back.

You can download a free copy of the report at: 
http://www.friendsofthecommons.org/stateofcommons0304.pdf

*3. Neuromarketing update: **Commercial Alert asks feds to investigate 
neuromarketing research at **Emory** **University*
Commercial Alert sent a letter today to the federal Office for Human 
Research Protections, requesting an investigation of whether 
neuromarketing experiments at Emory University have violated federal 
guidelines for research on human subjects.

These medical experiments on human subjects are unethical because they 
will likely be used to promote disease and human suffering.

If the Office for Human Research Protections finds that Emory violated 
federal ethics rules regarding experiments on human subjects, the entire 
University may lose its federal research funding.

The letter was sent to Dr. Kristina Borror, director of the Division of 
Compliance Oversight of the Office for Human Research Protections.  The 
letter follows.

http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/211

Dear Dr. Borror:

This letter constitutes a formal request to investigate Emory University 
to determine whether it has violated the principles of the Belmont 
Report, which governs research on human subjects.

Researchers at Emory's School of Medicine and Hospital are using 
functional Magnetic Resonance Imaging not for healing, but for marketing 
- "neuromarketing" in the term of this new trade. In the words of 
/Forbes/ magazine, they are experimenting on human subjects in order to 
"find the buy button inside the skull."[1]

It sounds like something that could have happened in the former Soviet 
Union, for purposes of behavior control. Yet it is happening right here 
in America - at Emory. "The neuroscience wing at Emory University," the 
/New York Times/ reports, "is the epicenter of the neuromarketing world."[2]

The ethical basis for this research is not readily apparent. According 
to news accounts, it is being done at Emory through an institute that 
does market research for corporate clients. Whatever its theoretical and 
hypothetical uses (and these are chilling for their own reasons) in 
actual practice it most likely will be used directly by these 
corporations to push products that are implicated in disease and human 
suffering and that impose greats costs upon individuals, families and 
the society at large.

The likely ill effects of this quest for the "buy button" are many, 
while the potential benefits are few, except to the corporations that 
will get to push that button. It is hard to see how this work fits 
within the principles of the Belmont Report, which requires that 
"research be justified on the basis of a favorable risk/benefit 
assessment," including social risks and benefits.

Emory's descent into neuromarketing is a project of something called the 
BrightHouse Institute for Thought Sciences, which is the leading 
neuromarketing research firm. (The name itself is Orwellian: the whole 
point of neuromarketing is to bypass thought, not encourage it.) 
According to the /Financial Times/, the BrightHouse Institute is "based 
in the neuroscience wing at Emory University Hospital."[3] The Institute 
in turn is part of BrightHouse, an advertising agency whose clients have 
included Coca-Cola, Pepperidge Farm, K-Mart and Home Depot. According to 
news accounts, BrightHouse uses the Emory University Hospital's 
functional Magnetic Resonance Imaging machine to conduct its 
neuromarketing experiments.

The BrightHouse website boasts of having the "most-advanced 
neuroscientific research capabilities and understanding of how the brain 
thinks, feels and motivates behavior." This knowledge of the brain 
enables corporations to "establish the foundation for loyal, 
long-lasting consumer relationships," the website says. Loyalty through 
brain mapping, in other words.

The BrightHouse Institute writes bluntly about its intention of 
"revolutionizing the marketing industry." According to a June 22, 2002 
news release, it

    plans to change the marketing world forever by using science to
    observe and understand the true drivers of consumer behavior. The
    Thought Sciences team uses functional Magnetic Resonance Imaging
    (fMRI), a safe and non-invasive technique, to identify patterns of
    brain activity that reveal how a consumer is actually evaluating a
    product, object or advertisement. Thought Sciences marketing
    analysts use this information to more accurately measure consumer
    preference, and then apply this knowledge to help marketers better
    create products and services and to design more effective marketing
    campaigns.[4]

What the neuromarketing research "really does" according to Adam Koval 
of the BrightHouse Institute, "is give unprecedented insight into the 
consumer mind. And it will actually result in higher product sales or in 
brand preference or in getting customers to behave the way they want 
them to behave."[5]

Let us repeat that. The goal of the neuromarketing research at Emory 
University lies in "/getting customers to behave the way [corporate 
advertisers] want them to behave./" (Emphasis supplied.)

The founder and chief executive officer of the BrightHouse Institute is 
Joseph Alden Reiman, an adjunct professor at Emory University's Goizueta 
Business School. According to the BrightHouse website, Reiman is also 
Senior Research Fellow in the Department of Psychiatry and Behavioral 
Sciences at Emory University School of Medicine. The "chief scientist" 
at the Institute is Clinton D. Kilts. Dr. Kilts is also professor and 
vice-chair for research in the Department of Psychiatry and Behavioral 
Sciences.

Dr. Kilts is an expert in addiction. He has published such articles as 
"Neural activity related to drug craving in cocaine addiction," and 
"Imaging the roles of the amygdala in drug addiction."[6]

Dr. Kilts's research interests include "drug craving induced by mental 
imagery of drug use-related scenes," according to his Emory University 
School of Medicine web page.[7] Is Dr. Kilts now using his knowledge of 
addiction to sell products such as Coke? Is he working on mental mapping 
to induce product cravings through the use of product-related scenes? 
Dr. Kilts has declined to respond to repeated calls regarding his 
neuromarketing research.

The Belmont Report requires a systematic assessment of risks and 
benefits in research on human subjects, and a finding that the benefits 
outweigh the risks. The risks of this research are obvious, as is the 
moral repulsiveness. The benefits are more questionable, except to 
corporations such as Coca-Cola.

At the most basic physical level, neurological marketing research relies 
on the use of Magnetic Resonance Imaging on human subjects. Strong 
magnets can harm human subjects if they have metal in their bodies (e.g. 
cardiac pacemaker, aneurism clips, intrauterine devices, some dental 
work, body piercings) or are carrying metal, such as coins or jewelry. 
Such harm is not likely but the possibility does exist. Research 
subjects occasionally report dizziness or nausea when their heads are 
moved within the bore of the magnet.

That's on top of any unknown adverse effects of placing a human subject 
in the intense magnetic field required for an MRI. It is hard to believe 
that this procedure is helpful when not medically required.

But such potential physical harms are secondary. The real risk of 
neuromarketing research is to the people - including children - who are 
probably the real targets of this research. Already, marketing is deeply 
implicated in many serious pathologies. That is especially true of 
children, who are suffering from an epidemic of marketing-related 
diseases,[8] including obesity,[9] type 2 diabetes[10] and 
alcoholism,[11] while millions will eventually die from smoking-related 
illnesses.[12] Gambling is a serious problem for millions of young 
people as well.[13]

Neurological marketing is a tool to amplify these trends. It is hard to 
think of a single benefit that could result from teaching corporate 
marketers how to press a "buy button" in the minds of individual 
Americans. Is there really a person in America who is insufficiently 
impelled to eat more Pepperidge Farm cookies or drink more Coke?

In effect, the BrightHouse Institute is conducting neuromarketing 
research at Emory University to develop tools of behavior control and 
behavior modification, which it is selling to its corporate clients.

The BrightHouse Institute explains that their

    Thought Sciences' team customizes each study to meet their clients
    needs. In a recent study, volunteers were used to test responses to
    food, advertisements, cars, and other topic categories. At the
    beginning of the study, the volunteers filled out a survey
    identifying likes and dislikes in eight different categories. Then,
    the volunteers were placed under the fMRI scanner and shown an item
    on a screen. While viewing the stimuli, Thought Sciences researchers
    took a picture of the volunteer's brain and compared the response of
    the brain to the response on the survey. From the results, the
    researchers pinpointed the preference area of the brain. Using this
    data, the Thought Sciences team can now help their client to design
    better products and services and a more effective marketing
    campaign.[14]

According to the /New York Times/, The BrightHouse Institute has a 
Fortune 500 client. But it refuses to identify the client. Who is the 
client? Is it a tobacco company? Why won't BrightHouse disclose its 
clients? What is it hiding? What precisely are these neuromarketing 
experiments that they are conducting at Emory University? How is their 
Fortune 500 client using the experiments? What advice is the BrightHouse 
Institute providing its clients, based on its neuromarketing research at 
Emory?

Since there are scores of potential problems with this neuromarketing 
research, we will point out a few obvious examples. What if 
neuromarketing research were employed by a corporation that manufactures 
cigarettes, for example? According to the /Morbidity and Mortality 
Weekly Report/, smoking "caused approximately 440,000 premature deaths 
in the United States annually."[15] If the neuromarketing experiments 
were relatively unsuccessful, and increased the number of smokers by a 
mere 0.1%, this might eventually cause approximately an extra 440 
premature deaths per year.

More broadly, what exactly will stop Emory's neuromarketing research 
from being sold to corporate clients to push the "buy button" for more 
tobacco, alcohol, junk food, violence, gambling and other addictive or 
destructive behaviors? Does Emory University have ethical standards 
regarding which corporate clients the BrightHouse Institute may consult 
for, and conduct experiments for? If so, what are those standards and 
how will they be enforced?

Some might protest that neuromarketing research could be used to shut a 
"buy button" off as well as on. Conceivably. But it is not clear why 
corporations would support research that will cause people to buy less 
of their products. If the university and the researchers involved were 
to sign written statements promising that this research would be used 
only for such purposes, on pain of stiff financial penalties, the 
argument might become remotely credible. But even then, the prospect of 
behavior control at that level has totalitarian implications that 
require much more discussion than has occurred to date.

Does the BrightHouse institute have any political clients? Any sale of 
neuromarketing research by the BrightHouse Institute to violent 
dictators or other political propagandists could potentially have 
devastating effects on entire countries. The history of the last century 
is filled with the tragic successes of propaganda in inducing whole 
populations to commit genocide. Many millions, if not tens of millions, 
of lives have been lost in these tragedies. What safeguards has Emory 
put into place to ensure that it is not used to create more effective 
political propaganda in support of genocide or the inflammation of 
racial or nationalistic hatreds?

Given the prospect of dubious social benefit and almost certain social 
harm, it is hard to see how Emory's neuromarketing research meets the 
risk-benefit calculus test of the Belmont Report for experimentation on 
human subjects. For identical reasons, the experiments also appear to 
violate the Belmont Report's requirement that experimentation on human 
subjects follow the related principle of "beneficence," because it is 
not the intention of the BrightHouse Institute's corporate clients to 
maximize social benefits and minimize social harms, but rather to 
manipulate people to buy products, irrespective of benefit or harm.

According to the /Atlanta Business Chronicle/, Dr. Robert Rich, 
executive associate dean for research at the Emory School of Medicine, 
defends the neuromarketing research by claiming that findings have been 
presented at a neuroscience conference, and will be published in medical 
journals.[16] Yet given the social harms that predictably will arise 
from the sale of this research to corporate clients, the claim that some 
of it might be presented at conferences or in journals is not exactly 
overwhelming.

In recent days, the BrightHouse Institute has launched a defense based 
on marketing jargon.

    We are a novel form of consumer consultancy that leverages
    scientific knowledge about how the human brain motivates consumer
    behavior to deliver strategic insights that are intended to enhance
    the relationship between the consumer and the product, brand and
    company. Our goal is to define the neural basis of behaviors that
    are of specific interest to strategic business decision making, as
    well as of generic interest to the field of neuroscience. We are not
    interested in telling companies what people think about their
    products, but rather how they think. Our focus is decidedly from the
    consumer perspective with the direct intent to influence the
    behavior of companies, rather than consumers.[17]

It's not really for their corporate clients. It's for the people whose 
"buy buttons" the corporations seek to push.

On December 1, 2003, Commercial Alert sent a letter to James Wagner, 
President of Emory University, warning him of the unethical 
neuromarketing research conducted at Emory.[18] Regrettably, there is no 
indication that he has halted the neuromarketing research. According to 
the /Atlanta Business Chronicle/, Dr. Robert Rich, executive associate 
dean for research at the Emory School of Medicine, who is responsible 
for overseeing the neuromarketing research, says that it will continue.[19]

Consequently, we strongly urge the Office of Human Research Protections 
to conduct a full and thorough investigation of Emory's research in the 
field of neuromarketing. Emory is on notice. It refuses to acknowledge 
even the possibility of a problem. Therefore, if you find that the 
University has violated the principles of the Belmont Report, we urge 
you to inflict the severest punishment upon the entire University, and 
to debar it from receiving federal research funding, according to the 
procedures of 45 CFR Part 76.

Thank you for your consideration.

Sincerely,

Gary Ruskin
Executive Director
--------------------------------------------------------------------------------
Footnotes

[1] Melanie Wells, "In Search of the 'Buy Button.'" 
<http://www.commercialalert.org/index.php/external/true/article_id/209> 
/Forbes/, September 1, 2003. See Attachment #1.

[2] Clive Thompson, "There's a Sucker Born in Every Medial Prefrontal 
Cortex." 
<http://www.commercialalert.org/index.php/external/true/article_id/207> 
/New York Times/, October 26, 2003. Jerome Burne, "A Probe Inside the 
Mind of the Shopper." 
<http://www.commercialalert.org/index.php/external/true/article_id/208> 
/Financial Times/, November 28, 2003. See Attachment #2.

[3] Jerome Burne, "A Probe Inside the Mind of the Shopper." /Financial 
Times/, November 28, 2003.

[4] "Brighthouse Institute For Thought Sciences Launches First 
"Neuromarketing" Research Company; Company Uses Neuroimaging To Unlock 
The Consumer Mind." BrightHouse Institute for Thought Sciences news 
release, June 22, 2002, 
http://www.prweb.com/releases/2002/6/prweb40936.php. See Attachment #3.

[5] "The Science of Shopping." CBC TV, December 3, 2002, 
http://www.cbc.ca/consumers/market/files/money/science_shopping/. See 
Attachment #4.

[6] PubMed listing of articles by Clinton D. Kilts 
<http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=search&db=PubMed&term=Kilts+CD%5BAU%5D+Emory%5BAD%5D>. 
See Attachment #5.

[7] Emory University School of Medicine faculty web page for Clinton D. 
Kilts Ph.D, 
http://www.medadm.emory.edu/FACULTY/index.taf?_function=profile&Faculty_uid1=116 
<http://www.medadm.emory.edu/FACULTY/index.taf?_function=profile&Faculty_uid1=116>. 
See Attachment #6.

[8] Jonathan Rowe and Gary Ruskin, "The Parents' Bill of Rights: Helping 
Moms and Dads Fight Commercialism." 
<http://www.alternet.org/story.html?StoryID=15754> /Mothering Magazine/, 
Jan/Feb 2003.

[9] Cynthia L. Ogden et al., "Prevalence and Trends in Overweight Among 
US Children and Adolescents, 1999-2000." /Journal of the American 
Medical Association/, October 9, 2002. JAMA 2002; 288:1728-1732.

[10] A.L. Rosenbloom et al.,"Emerging Epidemic of Type 2 Diabetes in 
Youth." /Diabetes Care/, February, 1999; 22(2): 345-54.

[11] "Underage Drinking: A Major Public Health Challenge." /Alcohol 
Alert/, National Institute on Alcohol Abuse and Alcoholism, April, 2003.

[12] "Annual Smoking-Attributable Mortality, Years of Potential Life 
Lost, and Economic Costs --- United States, 1995--1999." /Morbidity and 
Mortality Weekly Report/, April 12, 2002, 51(14);300-3.

[13] National Gambling Impact Study Commission, Final Report, p. 4-12.

[14] "Brighthouse Institute For Thought Sciences Launches First 
"Neuromarketing" Research Company; Company Uses Neuroimaging To Unlock 
The Consumer Mind." BrightHouse Institute for Thought Sciences news 
release, June 22, 2002, .

[15] "Annual Smoking-Attributable Mortality, Years of Potential Life 
Lost, and Economic Costs --- United States, 1995--1999." /Morbidity and 
Mortality Weekly Report/, April 12, 2002, 51(14);300-3.

[16] Jim Lovel, "Nader Group Slams Emory for Brain Research." 
<http://www.bizjournals.com/atlanta/stories/2003/12/08/story8.html> 
/Atlanta Business Chronicle/, December 8, 2003. Correspondence from Dr. 
Robert Rich to Commercial Alert, December 13, 2003. Email correspondence 
from Dr. Robert Rich to Commercial Alert, December 12, 2003. See 
Attachment #7.

[17] BrightHouse website, http://www.thoughtsciences.com/.

[18] Correspondence 
<http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/205> 
from Rev. Tom Grey, Jane M. Healy PhD, Susan Linn EdD, Jonathan Rowe, 
Gary Ruskin and V. Susan Villani MD to Emory University President James 
Wagner, December 1, 2003. See Attachment #8.

[19] Jim Lovel, "Nader Group Slams Emory for Brain Research." /Atlanta 
Business Chronicle/, December 8, 2003.

<------letter ends here----->
*BACKGROUND:*
For more information about neuromarketing, see Commercial Alert's 
neuromarketing web page, at: 
http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/202
*
ABOUT COMMERCIAL ALERT:*
Commercial Alert is a national nonprofit organization whose mission is 
to keep the commercial culture within its proper sphere, and to prevent 
it from exploiting children and subverting the higher values of family, 
community, environmental integrity and democracy. 

Commercial Alert has more than 2000 members, representing all 50 states 
and the District of Columbia. For more information, or to become a 
member, go to 
<https://www.groundspring.org/donate/index.cfm?ID=3D2404-0%7C1236-0>, or 
visit our website at http://www.commercialalert.org.

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per week, at most.

-- 
Gary Ruskin | Executive Director | Commercial Alert
gary@commercialalert.org | http://www.commercialalert.org/
Congressional Accountability Project | http://www.congressproject.org/
phone: 503.235.8012 | fax: 503.235.5073

To subscribe to Commercial Alert's email list, go to
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<b>Commercial Alert, December 17, 2003<br>
<br>
1. Thank you &amp; annual subscriber survey<br>
2. The State of the Commons report<br>
3. Neuromarketing update: </b><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><b style=""><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">Commercial
Alert asks feds to investigate neuromarketing research at </span></b><st1:place><st1:PlaceName><b
 style=""><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">Emory</span></b></st1:PlaceName><b
 style=""><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">
</span></b><st1:PlaceType><b style=""><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">University</span></b></st1:PlaceType></st1:place></span><br>
<br>
<b>1. Thank you &amp; annual subscriber survey<br>
<font face="Times New Roman, Times, serif"><br>
</font></b><font face="Times New Roman, Times, serif">Dear friends,
<br>
Thank you for subscribing to Commercial Alert's email newsletter.&nbsp;
We really appreciate your attention and support.&nbsp; <br>
<br>
Please take a moment
to fill out our short annual subscriber survey, and
return it to &lt;<a href="mailto:gary@commercialalert.org">gary@commercialalert.org</a>&gt;
We'd love to have your input to
improve our work and meet your needs as a subscriber.
<br>
<br>
* What are the strengths of our email newsletter?
<br>
* How can we improve our email newsletter?<br>
<br>
</font>Finally, will you become a member of Commercial Alert by making
a contribution?&nbsp; &nbsp;If you are already a member, will you renew your
membership for 2004?<font color="navy"><span style="color: navy;"><br>
<br>
</span></font>In 2004, Commercial Alert will stand up for you in the
fight to preserve our
culture from the rampant commercialism that is assaulting our health,
our values, our children, our schools and our government.<br>
<br>
<font face="Times New Roman, Times, serif">Commercial Alert now has
more than 2,000 members.&nbsp; This is good news.&nbsp;
Our goal is to
double
our membership in 2004.&nbsp; We can increase our political strength if you
join Commercial Alert today or renew your membership.&nbsp; All you need to
do is to give $15, $35, $50, $100 or more.&nbsp; Contribure today at <a
 href="https://secure.groundspring.org/dn/index.php?id=1236">https://secure.groundspring.org/dn/index.php?id=1236</a>
or send your check to Commercial Alert; 4110 SE Hawthorne Blvd. #123;
Portland, OR 97214.&nbsp; Thank you in advance for your generosity.<br>
</font><font size="2" face="Times New Roman, Times, serif"><span
 style="font-size: 10pt; font-family: Arial;"></span></font><font
 size="2" face="Times New Roman, Times, serif"><span
 style="font-size: 10pt; font-family: Arial;"><br>
</span></font><font face="Times New Roman, Times, serif">Happy holidays.<br>
<br>
Sincerely,
<br>
<br>
Gary Ruskin
<br>
Executive Director
<br>
Commercial Alert<br>
<br>
</font><b>2. The State of the Commons report<br>
</b>Our friends at the Friends of the Commons have produced a splendid
report titled "The State of the Commons."&nbsp; It's the best short
introduction yet to what the commons is, why it's important, how to
preserve it, how much it's worth, who's stealing it from us, and how we
can get it back.<br>
<br>
You can download a free copy of the report at: <a
 href="http://www.friendsofthecommons.org/stateofcommons0304.pdf">http://www.friendsofthecommons.org/stateofcommons0304.pdf</a><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><br>
<br>
<b>3. Neuromarketing update: </b></span><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><b style=""><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">Commercial
Alert asks feds to investigate neuromarketing research at </span></b><st1:place><st1:PlaceName><b
 style=""><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">Emory</span></b></st1:PlaceName><b
 style=""><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">
</span></b><st1:PlaceType><b style=""><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">University</span></b></st1:PlaceType></st1:place></span><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><br>
Commercial Alert sent a letter today to the
federal Office for Human Research Protections, requesting an
investigation of whether
neuromarketing experiments at </span><st1:place><st1:PlaceName><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">Emory</span></st1:PlaceName><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"> </span><st1:PlaceType><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">University</span></st1:PlaceType></st1:place><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"> have
violated federal guidelines for research on
human subjects. <br>
</span><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"></span><br>
These medical experiments on human subjects are unethical
because they will likely be used to promote disease and human suffering.<br>
<p class="MsoNormal">If the Office for Human Research Protections finds
that Emory violated federal
ethics rules regarding experiments on human subjects, the entire
University may lose its
federal
research funding.<o:p></o:p></p>
<p class="MsoNormal"><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;">The letter
was sent to Dr. Kristina Borror, director of
the Division of Compliance Oversight of the Office for Human Research
Protections.<span style="">&nbsp; </span>The letter follows.</span><br>
</p>
<span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"></span><span
 style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><a
 href="http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/211">http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/211</a><br>
<br>
Dear Dr.
Borror:<br>
<br>
This letter constitutes a formal request to investigate Emory
University to determine whether it has violated the principles of the
Belmont Report, which governs research on human subjects.<br>
<br>
Researchers at Emory&#8217;s School of Medicine and Hospital are using
functional Magnetic Resonance Imaging not for healing, but for
marketing &#8211; &#8220;neuromarketing&#8221; in the term of this new trade. In the
words of <i>Forbes</i> magazine, they are experimenting on human
subjects in order to &#8220;find the buy button inside the skull.&#8221;[1] <br>
<br>
It sounds like something that could have happened in the former Soviet
Union, for purposes of behavior control. Yet it is happening right here
in America &#8211; at Emory. &#8220;The neuroscience wing at Emory University,&#8221; the
<i>New York Times</i> reports, &#8220;is the epicenter of the neuromarketing
world.&#8221;[2]<br>
<br>
The ethical basis for this research is not readily apparent. According
to news accounts, it is being done at Emory through an institute that
does market research for corporate clients. Whatever its theoretical
and hypothetical uses (and these are chilling for their own reasons) in
actual practice it most likely will be used directly by these
corporations to push products that are implicated in disease and human
suffering and that impose greats costs upon individuals, families and
the society at large. <br>
<br>
The likely ill effects of this quest for the &#8220;buy button&#8221; are many,
while the potential benefits are few, except to the corporations that
will get to push that button. It is hard to see how this work fits
within the principles of the Belmont Report, which requires that
&#8220;research be justified on the basis of a favorable risk/benefit
assessment,&#8221; including social risks and benefits.<br>
<br>
Emory&#8217;s descent into neuromarketing is a project of something called
the BrightHouse Institute for Thought Sciences, which is the leading
neuromarketing research firm. (The name itself is Orwellian: the whole
point of neuromarketing is to bypass thought, not encourage it.)
According to the <i>Financial Times</i>, the BrightHouse Institute is
&#8220;based in the neuroscience wing at Emory University Hospital.&#8221;[3] The
Institute in turn is part of BrightHouse, an advertising agency whose
clients have included Coca-Cola, Pepperidge Farm, K-Mart and Home
Depot. According to news accounts, BrightHouse uses the Emory
University Hospital&#8217;s functional Magnetic Resonance Imaging machine to
conduct its neuromarketing experiments.<br>
<br>
The BrightHouse website boasts of having the &#8220;most-advanced
neuroscientific research capabilities and understanding of how the
brain thinks, feels and motivates behavior.&#8221; This knowledge of the
brain enables corporations to &#8220;establish the foundation for loyal,
long-lasting consumer relationships,&#8221; the website says. Loyalty through
brain mapping, in other words. <br>
<br>
The BrightHouse Institute writes bluntly about its intention of
&#8220;revolutionizing the marketing industry.&#8221; According to a June 22, 2002
news release, it <br>
</span>
<blockquote>
  <p>plans to change the marketing world forever by using science to
observe and understand the true drivers of consumer behavior. The
Thought Sciences team uses functional Magnetic Resonance Imaging
(fMRI), a safe and non-invasive technique, to identify patterns of
brain activity that reveal how a consumer is actually evaluating a
product, object or advertisement. Thought Sciences marketing analysts
use this information to more accurately measure consumer preference,
and then apply this knowledge to help marketers better create products
and services and to design more effective marketing campaigns.[4]</p>
</blockquote>
What the neuromarketing research &#8220;really does&#8221; according to Adam Koval
of the BrightHouse Institute, &#8220;is give unprecedented insight into the
consumer mind. And it will actually result in higher product sales or
in brand preference or in getting customers to behave the way they want
them to behave.&#8221;[5] <br>
<br>
Let us repeat that. The goal of the neuromarketing research at Emory
University lies in &#8220;<i>getting customers to behave the way [corporate
advertisers] want them to behave.</i>&#8221; (Emphasis supplied.)<br>
<br>
The founder and chief executive officer of the BrightHouse Institute is
Joseph Alden Reiman, an adjunct professor at Emory University&#8217;s
Goizueta Business School. According to the BrightHouse website, Reiman
is also Senior Research Fellow in the Department of Psychiatry and
Behavioral Sciences at Emory University School of Medicine. The &#8220;chief
scientist&#8221; at the Institute is Clinton D. Kilts. Dr. Kilts is also
professor and vice-chair for research in the Department of Psychiatry
and Behavioral Sciences. <br>
<br>
Dr. Kilts is an expert in addiction. He has published such articles as
&#8220;Neural activity related to drug craving in cocaine addiction,&#8221; and
&#8220;Imaging the roles of the amygdala in drug addiction.&#8221;[6]<br>
<br>
Dr. Kilts&#8217;s research interests include &#8220;drug craving induced by mental
imagery of drug use-related scenes,&#8221; according to his Emory University
School of Medicine web page.[7] Is Dr. Kilts now using his knowledge of
addiction to sell products such as Coke? Is he working on mental
mapping to induce product cravings through the use of product-related
scenes? Dr. Kilts has declined to respond to repeated calls regarding
his neuromarketing research. <br>
<br>
The Belmont Report requires a systematic assessment of risks and
benefits in research on human subjects, and a finding that the benefits
outweigh the risks. The risks of this research are obvious, as is the
moral repulsiveness. The benefits are more questionable, except to
corporations such as Coca-Cola.<br>
<br>
At the most basic physical level, neurological marketing research
relies on the use of Magnetic Resonance Imaging on human subjects.
Strong magnets can harm human subjects if they have metal in their
bodies (e.g. cardiac pacemaker, aneurism clips, intrauterine devices,
some dental work, body piercings) or are carrying metal, such as coins
or jewelry. Such harm is not likely but the possibility does exist.
Research subjects occasionally report dizziness or nausea when their
heads are moved within the bore of the magnet. <br>
<br>
That&#8217;s on top of any unknown adverse effects of placing a human subject
in the intense magnetic field required for an MRI. It is hard to
believe that this procedure is helpful when not medically required. <br>
<br>
But such potential physical harms are secondary. The real risk of
neuromarketing research is to the people &#8211; including children &#8211; who are
probably the real targets of this research. Already, marketing is
deeply implicated in many serious pathologies. That is especially true
of children, who are suffering from an epidemic of marketing-related
diseases,[8] including obesity,[9] type 2 diabetes[10] and
alcoholism,[11] while millions will eventually die from smoking-related
illnesses.[12] Gambling is a serious problem for millions of young
people as well.[13]<br>
<br>
Neurological marketing is a tool to amplify these trends. It is hard to
think of a single benefit that could result from teaching corporate
marketers how to press a &#8220;buy button&#8221; in the minds of individual
Americans. Is there really a person in America who is insufficiently
impelled to eat more Pepperidge Farm cookies or drink more Coke? <br>
<br>
In effect, the BrightHouse Institute is conducting neuromarketing
research at Emory University to develop tools of behavior control and
behavior modification, which it is selling to its corporate clients.<br>
<br>
The BrightHouse Institute explains that their <br>
<blockquote>
  <p>Thought Sciences&#8217; team customizes each study to meet their clients
needs. In a recent study, volunteers were used to test responses to
food, advertisements, cars, and other topic categories. At the
beginning of the study, the volunteers filled out a survey identifying
likes and dislikes in eight different categories. Then, the volunteers
were placed under the fMRI scanner and shown an item on a screen. While
viewing the stimuli, Thought Sciences researchers took a picture of the
volunteer&#8217;s brain and compared the response of the brain to the
response on the survey. From the results, the researchers pinpointed
the preference area of the brain. Using this data, the Thought Sciences
team can now help their client to design better products and services
and a more effective marketing campaign.[14]</p>
</blockquote>
According to the <i>New York Times</i>, The BrightHouse Institute has
a Fortune 500 client. But it refuses to identify the client. Who is the
client? Is it a tobacco company? Why won&#8217;t BrightHouse disclose its
clients? What is it hiding? What precisely are these neuromarketing
experiments that they are conducting at Emory University? How is their
Fortune 500 client using the experiments? What advice is the
BrightHouse Institute providing its clients, based on its
neuromarketing research at Emory?<br>
<br>
Since there are scores of potential problems with this neuromarketing
research, we will point out a few obvious examples. What if
neuromarketing research were employed by a corporation that
manufactures cigarettes, for example? According to the <i>Morbidity
and Mortality Weekly Report</i>, smoking &#8220;caused approximately 440,000
premature deaths in the United States annually.&#8221;[15] If the
neuromarketing experiments were relatively unsuccessful, and increased
the number of smokers by a mere 0.1%, this might eventually cause
approximately an extra 440 premature deaths per year.<br>
<br>
More broadly, what exactly will stop Emory&#8217;s neuromarketing research
from being sold to corporate clients to push the "buy button" for more
tobacco, alcohol, junk food, violence, gambling and other addictive or
destructive behaviors? Does Emory University have ethical standards
regarding which corporate clients the BrightHouse Institute may consult
for, and conduct experiments for? If so, what are those standards and
how will they be enforced? <br>
<br>
Some might protest that neuromarketing research could be used to shut a
&#8220;buy button&#8221; off as well as on. Conceivably. But it is not clear why
corporations would support research that will cause people to buy less
of their products. If the university and the researchers involved were
to sign written statements promising that this research would be used
only for such purposes, on pain of stiff financial penalties, the
argument might become remotely credible. But even then, the prospect of
behavior control at that level has totalitarian implications that
require much more discussion than has occurred to date. <br>
<br>
Does the BrightHouse institute have any political clients? Any sale of
neuromarketing research by the BrightHouse Institute to violent
dictators or other political propagandists could potentially have
devastating effects on entire countries. The history of the last
century is filled with the tragic successes of propaganda in inducing
whole populations to commit genocide. Many millions, if not tens of
millions, of lives have been lost in these tragedies. What safeguards
has Emory put into place to ensure that it is not used to create more
effective political propaganda in support of genocide or the
inflammation of racial or nationalistic hatreds?<br>
<br>
Given the prospect of dubious social benefit and almost certain social
harm, it is hard to see how Emory&#8217;s neuromarketing research meets the
risk-benefit calculus test of the Belmont Report for experimentation on
human subjects. For identical reasons, the experiments also appear to
violate the Belmont Report&#8217;s requirement that experimentation on human
subjects follow the related principle of &#8220;beneficence,&#8221; because it is
not the intention of the BrightHouse Institute&#8217;s corporate clients to
maximize social benefits and minimize social harms, but rather to
manipulate people to buy products, irrespective of benefit or harm.<br>
<br>
According to the <i>Atlanta Business Chronicle</i>, Dr. Robert Rich,
executive associate dean for research at the Emory School of Medicine,
defends the neuromarketing research by claiming that findings have been
presented at a neuroscience conference, and will be published in
medical journals.[16] Yet given the social harms that predictably will
arise from the sale of this research to corporate clients, the claim
that some of it might be presented at conferences or in journals is not
exactly overwhelming.<br>
<br>
In recent days, the BrightHouse Institute has launched a defense based
on marketing jargon. <br>
<blockquote>
  <p>We are a novel form of consumer consultancy that leverages
scientific knowledge about how the human brain motivates consumer
behavior to deliver strategic insights that are intended to enhance the
relationship between the consumer and the product, brand and company.
Our goal is to define the neural basis of behaviors that are of
specific interest to strategic business decision making, as well as of
generic interest to the field of neuroscience. We are not interested in
telling companies what people think about their products, but rather
how they think. Our focus is decidedly from the consumer perspective
with the direct intent to influence the behavior of companies, rather
than consumers.[17]</p>
</blockquote>
It&#8217;s not really for their corporate clients. It&#8217;s for the people whose
&#8220;buy buttons&#8221; the corporations seek to push.<br>
<br>
On December 1, 2003, Commercial Alert sent a letter to James Wagner,
President of Emory University, warning him of the unethical
neuromarketing research conducted at Emory.[18] Regrettably, there is
no indication that he has halted the neuromarketing research. According
to the <i>Atlanta Business Chronicle</i>, Dr. Robert Rich, executive
associate dean for research at the Emory School of Medicine, who is
responsible for overseeing the neuromarketing research, says that it
will continue.[19]<br>
<br>
Consequently, we strongly urge the Office of Human Research Protections
to conduct a full and thorough investigation of Emory&#8217;s research in the
field of neuromarketing. Emory is on notice. It refuses to acknowledge
even the possibility of a problem. Therefore, if you find that the
University has violated the principles of the Belmont Report, we urge
you to inflict the severest punishment upon the entire University, and
to debar it from receiving federal research funding, according to the
procedures of 45 CFR Part 76. <br>
<br>
Thank you for your consideration. <br>
<br>
Sincerely,<br>
<br>
Gary Ruskin<br>
Executive Director<br>
--------------------------------------------------------------------------------<br>
Footnotes<br>
<br>
[1] Melanie Wells, <a
 href="http://www.commercialalert.org/index.php/external/true/article_id/209"
 target="_blank">"In
Search of the &#8216;Buy Button.&#8217;&#8221;</a> <i>Forbes</i>, September 1, 2003. See
Attachment #1.<br>
<br>
[2] Clive Thompson, <a
 href="http://www.commercialalert.org/index.php/external/true/article_id/207"
 target="_blank">&#8220;There&#8217;s
a Sucker Born in Every Medial Prefrontal Cortex.&#8221;</a> <i>New York Times</i>,
October 26, 2003. Jerome Burne, <a
 href="http://www.commercialalert.org/index.php/external/true/article_id/208"
 target="_blank">&#8220;A
Probe Inside the Mind of the Shopper.&#8221;</a> <i>Financial Times</i>,
November 28, 2003. See Attachment #2.<br>
<br>
[3] Jerome Burne, &#8220;A Probe Inside the Mind of the Shopper.&#8221; <i>Financial
Times</i>, November 28, 2003.<br>
<br>
[4] "Brighthouse Institute For Thought Sciences Launches First
&#8220;Neuromarketing&#8221; Research Company; Company Uses Neuroimaging To Unlock
The Consumer Mind.&#8221; BrightHouse Institute for Thought Sciences news
release, June 22, 2002, <a
 href="http://www.prweb.com/releases/2002/6/prweb40936.php"
 target="_blank">http://www.prweb.com/releases/2002/6/prweb40936.php</a>.
See Attachment #3.<br>
<br>
[5] &#8220;The Science of Shopping.&#8221; CBC TV, December 3, 2002, <a
 href="http://www.cbc.ca/consumers/market/files/money/science_shopping/"
 target="_blank">http://www.cbc.ca/consumers/market/files/money/science_shopping/</a>.
See Attachment #4.<br>
<br>
[6] PubMed listing of <a
 href="http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=search&amp;db=PubMed&amp;term=Kilts+CD%5BAU%5D+Emory%5BAD%5D"
 target="_blank">articles
by Clinton D. Kilts</a>. See Attachment #5.<br>
<br>
[7] Emory University School of Medicine faculty web page for Clinton D.
Kilts Ph.D, <a
 href="http://www.medadm.emory.edu/FACULTY/index.taf?_function=profile&amp;Faculty_uid1=116"
 target="_blank">http://www.medadm.emory.edu/FACULTY/index.taf?_function=profile&amp;Faculty_uid1=116</a>.
See Attachment #6.<br>
<br>
[8] Jonathan Rowe and Gary Ruskin, <a
 href="http://www.alternet.org/story.html?StoryID=15754" target="_blank">&#8220;The
Parents&#8217;
Bill of Rights: Helping Moms and Dads Fight Commercialism.&#8221;</a> <i>Mothering
Magazine</i>, Jan/Feb 2003.<br>
<br>
[9] Cynthia L. Ogden et al., &#8220;Prevalence and Trends in Overweight Among
US Children and Adolescents, 1999-2000.&#8221; <i>Journal of the American
Medical Association</i>, October 9, 2002. JAMA 2002; 288:1728-1732. <br>
<br>
[10] A.L. Rosenbloom et al.,&#8220;Emerging Epidemic of Type 2 Diabetes in
Youth.&#8221; <i>Diabetes Care</i>, February, 1999; 22(2): 345-54.<br>
<br>
[11] &#8220;Underage Drinking: A Major Public Health Challenge.&#8221; <i>Alcohol
Alert</i>, National Institute on Alcohol Abuse and Alcoholism, April,
2003.<br>
<br>
[12] &#8220;Annual Smoking-Attributable Mortality, Years of Potential Life
Lost, and Economic Costs --- United States, 1995&#8212;1999.&#8221; <i>Morbidity
and Mortality Weekly Report</i>, April 12, 2002, 51(14);300-3.<br>
<br>
[13] National Gambling Impact Study Commission, Final Report, p. 4-12.<br>
<br>
[14] &#8220;Brighthouse Institute For Thought Sciences Launches First
&#8220;Neuromarketing&#8221; Research Company; Company Uses Neuroimaging To Unlock
The Consumer Mind.&#8221; BrightHouse Institute for Thought Sciences news
release, June 22, 2002, <HTTP: prweb40936.php="" 6="" 2002=""
 releases="" www.prweb.com="">.<br>
<br>
[15] &#8220;Annual Smoking-Attributable Mortality, Years of Potential Life
Lost, and Economic Costs --- United States, 1995&#8212;1999.&#8221; <i>Morbidity
and Mortality Weekly Report</i>, April 12, 2002, 51(14);300-3.<br>
<br>
[16] Jim Lovel, <a
 href="http://www.bizjournals.com/atlanta/stories/2003/12/08/story8.html"
 target="_blank">&#8220;Nader
Group Slams Emory for Brain Research.&#8221;</a> <i>Atlanta Business
Chronicle</i>, December 8, 2003. Correspondence from Dr. Robert Rich to
Commercial Alert, December 13, 2003. Email correspondence from Dr.
Robert Rich to Commercial Alert, December 12, 2003. See Attachment #7.<br>
<br>
[17] BrightHouse website, <a href="http://www.thoughtsciences.com/"
 target="_blank">http://www.thoughtsciences.com/</a>.<br>
<br>
[18] <a
 href="http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/205"
 target="_blank">Correspondence</a>
from Rev. Tom Grey, Jane M. Healy PhD, Susan Linn EdD, Jonathan Rowe,
Gary Ruskin and V. Susan Villani MD to Emory University President James
Wagner, December 1, 2003. See Attachment #8.<br>
<br>
[19] Jim Lovel, &#8220;Nader Group Slams Emory for Brain Research.&#8221; <i>Atlanta
Business Chronicle</i>, December 8, 2003.<br>
<br>
&lt;------letter ends here-----&gt;<br>
</HTTP:><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><b>BACKGROUND:</b><br>
For more information about neuromarketing, see Commercial
Alert&#8217;s neuromarketing web page, at: <a
 href="http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/202">http://www.commercialalert.org/index.php/category_id/1/subcategory_id/82/article_id/202</a><br>
</span><b><br>
ABOUT COMMERCIAL
ALERT:</b><span style=""><br>
Commercial Alert is
a national nonprofit organization whose mission is to keep the
commercial
culture within its proper sphere, and to prevent it from exploiting
children
and subverting the higher values of family, community, environmental
integrity
and democracy.<span style="">&nbsp; </span><o:p></o:p></span>
<p class="MsoNormal"></p>
<p class="MsoNormal"><span style="">Commercial Alert has
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 style="">District of Columbia</span></st1:place></st1:state><span
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or visit our website at <a class="moz-txt-link-freetext"
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</span><span style="font-size: 12pt; font-family: &quot;Times New Roman&quot;;"><br>
</span>
<pre class="moz-signature" cols="72">-- 
Gary Ruskin | Executive Director | Commercial Alert
<a class="moz-txt-link-abbreviated"
 href="mailto:gary@commercialalert.org">gary@commercialalert.org</a> | <a
 class="moz-txt-link-freetext" href="http://www.commercialalert.org/">http://www.commercialalert.org/</a>
Congressional Accountability Project | <a
 class="moz-txt-link-freetext" href="http://www.congressproject.org/">http://www.congressproject.org/</a>
phone: 503.235.8012 | fax: 503.235.5073

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