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«October 26, 2015 Donald S. Clark Federal Trade Commission Office of the Secretary 600 Pennsylvania Avenue NW. Suite CC–5610 (Annex C) Washington, ...»

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11. What evidence is available concerning the degree of industry compliance with the Rule?

It is clear there is wide spread non-compliance with several components of the Rule.

1. Selling Lenses Without a Prescription: There are many retailers selling contact lenses without a prescription when the Act and Rule “prohibit any person that engages in the manufacture, processing, assembly, sale, offering for sale, or distribution of contact lenses from representing, by advertisement, sales presentation, or otherwise, that contact lenses may be obtained without a prescription." A listing of websites potentially violating this requirement is included below in Appendix B. These larger retailers violate the Rule along with individuals who attempt to sell contact lenses through websites such as Facebook, eBay, and Amazon.com.

2. Selling Lenses With an Expired Prescription: Consumers have acknowledged in several surveys or studies they often buy contact lenses after their prescription has expired. Some sellers ask customers to reorder lenses after the prescription has expired.

An expired prescription is an invalid prescription, and sellers should not knowingly seek to verify an invalid prescription.

3. Quantities of Lenses: Retailers who allow patients to purchase large amounts of contact lenses beyond what is reasonably necessary for the duration of a prescription also violate the pro-competitive benefits of the Rule (See Appendix A) by restricting a patient to a single seller for potentially many years.

4. Incomplete Robocalls: While the AOA believes the Rule should no longer allow robocalls to be used to verify prescriptions, the Rule is clear in that “calls from automated telephone systems must fully comply with all applicable Rule requirements” just like calls that are not robocalls. The AOA often hears from doctors of optometry who indicate the information received via phone was not complete and did not provide sufficient information to verify a prescription.

5. Lack of Retailer Contact Person: While the Rule specifies retailers must have a contact person who is “reasonably accessible to the prescriber,” the AOA has received many reports from doctors of optometry that it is extremely difficult to get in contact with anyone at 1-800 CONTACTS to discuss problems with a patient’s order. Therefore the AOA strongly urges the FTC to require sellers to respond to prescriber verification questions within eight business hours and prior to any sale.

6. Brand Switching: While the Rule indicates a ‘‘seller may not alter a contact lens prescription," the AOA has received reports from members that patients have been able to select lenses from online retailers other than those prescribed by their doctor.

12. What modifications, if any, should be made to the Rule to account for changes in relevant technology or economic conditions? What evidence supports the proposed modifications?

As is detailed above in questions 8-12, allowing the use of robocalls must be eliminated. This revision would account for changes in technology and an overall attitude shift regarding the use of automated phone calls that has occurred in the ten years since the Rule was drafted.

14 The AOA stands ready to assist the FTC in working towards the best and safest contact lens market for patients. We appreciate the opportunity to comment on this Rule. If you have questions or need additional information, please contact Rodney Peele, Associate General Counsel for Public Policy, at rpeele@aoa.org Sincerely, Steven A. Loomis, O.D.

AOA President

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GROUPON “Non-Prescription Contact Lenses” 23

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