January 30, 2017
Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue NW, Suite CC-5610 (Annex C)
Washington, DC 20850
Re: Contact Lens Rule, 16 CFR part 315, Project No. R511995
To Whom It May Concern:
In October 2015, I submitted comments to the Federal Trade Commission (“Commission”) regarding the Contact Lens Rule (“CLR”). In those comments, I addressed some of the issues that I had become aware of in the contact lens industry after I had sponsored legislation in the State of Rhode Island that would protect contact lens wearers from anti-competitive pricing policies by the contact lens manufacturers. After an extensive legislative hearing on that proposal, it became very clear that some of the issues that surfaced included the lack of compliance with the requirement to automatically release contact lens prescriptions to patients, the slanted process for filing complaints that favored the eye care providers, and the interference with consumers and their ability to purchase from third party resellers.