From Our Members

Jan 23, 2017 Comment Letter to FTC

As a leading online retailer to millions of Americans looking for the best prices on high quality contacts, compliments the Federal Trade Commission (FTC) on the recently released contact lens rule and respectfully submits this letter in strong support of its full support as drafted.

Tens of millions of Americans who wear contact lenses will benefit from the rule the Federal Trade Commission has proposed. Optometrists will continue to be required by law as outlined in the Fairness to Contact Lens Consumers Act (FCLCA) to hand patients a copy of their prescription for contact lenses so those patients can decide for themselves where to purchase their lenses.

In a pro-consumer change, the Commission has proposed that optometrists now also be required to obtain a patient’s signature acknowledging that their optometrist provided the prescription. This is because many optometrists do not provide patients with their prescriptions despite being required to by law, because optometry offices actually make a significant portion of their revenue from selling contact lenses, not providing just eye care services. supports this proposed action by the Commission.

We believe this is a significant change and a real win for consumers. Back in 2004, Congress passed the FCLCA, which required optometrists to hand patients their contact lens prescription, so that patients could comparison shop for a better price. The law created a thriving, robust marketplace in which new market entrants and vigorous competition developed. This has driven prices down for consumers and led to new innovations in the market. However today, over a decade after the FCLCA passed into law, in excess of two-thirds of customers still order without the ease of using their prescription. Surely this is a direct result of the failure of optometrists to provide their patients with their prescriptions, as required by law. This forces to contact the optometrist directly and await a response, unnecessarily delaying the shipment of the contact lenses to the customer. The Federal Trade Commission has been working on this rule for over a year, looking into the behavior of optometrists and has found what we have known for years: many still do not provide their patents with prescriptions as required by law. is grateful to the Commission for the hard work and investigation put into these findings.

Similarly, we strongly endorse the Commission’s findings with regards to the rejection of health claims made by the AOA and the Commission’s decisions to reject efforts to weaken the strong pro-consumer portions of the existing rule suggested by lens manufacturers and the AOA, specifically those concerning prescription verification.

The FTC has put a tremendous amount of work and consideration into the promulgation of this rule. is grateful, and our millions of customers will benefit as a result. The nation’s 40 million contact lens wearers owe the Commission and staff a great debt. Please move with all haste to promulgate the rule as drafted.

With Best Regards,

Cary Samourkachian

See the Letter