For proper brain function, our CNS (Central Nervous System) requires several amino acids. These derive from protein-rich foods. Consider amino acids to be protein building blocks. Many of them are dietary precursors to vital neurotransmitters in our brain. Epinephrine (adrenaline), serotonin, dopamine, and norepinephrine assist in enhancing mental performance. A few examples of amino acid nootropics are:
An additional complexity, related to individual differences, concerns dosage. This factor, which varies across studies and may be fixed or determined by participant body weight within a study, undoubtedly influences the cognitive effects of stimulant drugs. Furthermore, single-unit recordings with animals and, more recently, imaging of humans indicate that the effects of stimulant dose are nonmonotonic; increases enhance prefrontal function only up to a point, with further increases impairing function (e.g., Arnsten, 1998; Mattay et al., 2003; Robbins & Arnsten, 2009). Yet additional complexity comes from the fact that the optimal dosage depends on the same kinds of individual characteristics just discussed and on the task (Mattay et al., 2003).
The absence of a suitable home for this needed research on the current research funding landscape exemplifies a more general problem emerging now, as applications of neuroscience begin to reach out of the clinical setting and into classrooms, offices, courtrooms, nurseries, marketplaces, and battlefields (Farah, 2011). Most of the longstanding sources of public support for neuroscience research are dedicated to basic research or medical applications. As neuroscience is increasingly applied to solving problems outside the medical realm, it loses access to public funding. The result is products and systems reaching the public with less than adequate information about effectiveness and/or safety. Examples include cognitive enhancement with prescription stimulants, event-related potential and fMRI-based lie detection, neuroscience-based educational software, and anti-brain-aging computer programs. Research and development in nonmedical neuroscience are now primarily the responsibility of private corporations, which have an interest in promoting their products. Greater public support of nonmedical neuroscience research, including methods of cognitive enhancement, will encourage greater knowledge and transparency concerning the efficacy and safety of these products and will encourage the development of products based on social value rather than profit value.
One study of helicopter pilots suggested that 600 mg of modafinil given in three doses can be used to keep pilots alert and maintain their accuracy at pre-deprivation levels for 40 hours without sleep.[60] However, significant levels of nausea and vertigo were observed. Another study of fighter pilots showed that modafinil given in three divided 100 mg doses sustained the flight control accuracy of sleep-deprived F-117 pilots to within about 27% of baseline levels for 37 hours, without any considerable side effects.[61] In an 88-hour sleep loss study of simulated military grounds operations, 400 mg/day doses were mildly helpful at maintaining alertness and performance of subjects compared to placebo, but the researchers concluded that this dose was not high enough to compensate for most of the effects of complete sleep loss.

We reached out to several raw material manufacturers and learned that Phosphatidylserine and Huperzine A are in short supply. We also learned that these ingredients can be pricey, incentivizing many companies to cut corners.  A company has to have the correct ingredients in the correct proportions in order for a brain health formula to be effective. We learned that not just having the two critical ingredients was important – but, also that having the correct supporting ingredients was essential in order to be effective.

Googling, you sometimes see correlational studies like Intake of Flavonoid-Rich Wine, Tea, and Chocolate by Elderly Men and Women Is Associated with Better Cognitive Test Performance; in this one, the correlated performance increase from eating chocolate was generally fairly modest (say, <10%), and the maximum effects were at 10g/day of what was probably milk chocolate, which generally has 10-40% chocolate liquor in it, suggesting any experiment use 1-4g. More interesting is the blind RCT experiment Consumption of cocoa flavanols results in acute improvements in mood and cognitive performance during sustained mental effort11, which found improvements at ~1g; the most dramatic improvement of the 4 tasks (on the Threes correct) saw a difference of 2 to 6 at the end of the hour of testing, while several of the other tests converged by the end or saw the controls winning (Sevens correct). Crews et al 2008 found no cognitive benefit, and an fMRI experiment found the change in brain oxygen levels it wanted but no improvement to reaction times.
In paired-associates learning, subjects are presented with pairs of stimuli and must learn to recall the second item of the pair when presented with the first. For these tasks, as with tasks involving memory for individual items, there is a trend for stimulants to enhance performance with longer delays. For immediate measures of learning, no effects of d-AMP or MPH were observed by Brumaghim and Klorman (1998); Fleming et al. (1995); Hurst, Radlow, and Weidner (1968); or Strauss et al. (1984). However, when Hurst et al.’s subjects were tested a week later, they recalled more if their initial learning had been carried out with d-AMP than with placebo. Weitzner (1965) assessed paired-associates learning with an immediate cued-recall test and found facilitation when the associate word was semantically related to the cue, provided it was not also related to other cue words. Finally, Burns, House, French, and Miller (1967) found a borderline-significant impairment of performance with d-AMP on a nonverbal associative learning task.
It was a productive hour, sure. But it also bore a remarkable resemblance to the normal editing process. I had imagined that the magical elixir coursing through my bloodstream would create towering storm clouds in my brain which, upon bursting, would rain cinematic adjectives onto the page as fast my fingers could type them. Unfortunately, the only thing that rained down were Google searches that began with the words "synonym for"—my usual creative process.
“I cannot overstate how grateful I am to Cavin for having published this book (and launched his podcast) before I needed it. I am 3.5 months out from a concussion and struggling to recover that final 25% or so of my brain and function. I fully believe that diet and lifestyle can help heal many of our ills, and this book gives me a path forward right now. Gavin’s story is inspiring, and his book is well-researched and clearly written. I am a food geek and so innately understand a lot of his advice — I’m not intimidated by the thought of drastically changing my diet because I know well how to shop and cook for myself — but I so appreciate how his gentle approach and stories about his own struggles with a new diet might help people who would find it all daunting. I am in week 2 of following his advice (and also Dr. Titus Chiu’s BrainSave plan). It’s not an instantaneous miracle cure, but I do feel better in several ways that just might be related to this diet.”
It is not because of the few thousand francs which would have to be spent to put a roof [!] over the third-class carriages or to upholster the third-class seats that some company or other has open carriages with wooden benches. What the company is trying to do is to prevent the passengers who can pay the second class fare from traveling third class; it hits the poor, not because it wants to hurt them, but to frighten the rich. And it is again for the same reason that the companies, having proved almost cruel to the third-class passengers and mean to the second-class ones, become lavish in dealing with first-class passengers. Having refused the poor what is necessary, they give the rich what is superfluous.

Feeling behind, I resolved to take some armodafinil the next morning, which I did - but in my hurry I failed to recall that 200mg armodafinil was probably too much to take during the day, with its long half life. As a result, I felt irritated and not that great during the day (possibly aggravated by some caffeine - I wish some studies would be done on the possible interaction of modafinil and caffeine so I knew if I was imagining it or not). Certainly not what I had been hoping for. I went to bed after midnight (half an hour later than usual), and suffered severe insomnia. The time wasn’t entirely wasted as I wrote a short story and figured out how to make nicotine gum placebos during the hours in the dark, but I could have done without the experience. All metrics omitted because it was a day usage.

Increasing incidences of chronic diseases such as diabetes and cancer are also impacting positive growth for the global smart pills market. The above-mentioned factors have increased the need for on-site diagnosis, which can be achieved by smart pills. Moreover, the expanding geriatric population and the resulting increasing in degenerative diseases has increased demand for smart pills
If you want to try a nootropic in supplement form, check the label to weed out products you may be allergic to and vet the company as best you can by scouring its website and research basis, and talking to other customers, Kerl recommends. "Find one that isn't just giving you some temporary mental boost or some quick fix – that’s not what a nootropic is intended to do," Cyr says.
Lebowitz says that if you're purchasing supplements to improve your brain power, you're probably wasting your money. "There is nothing you can buy at your local health food store that will improve your thinking skills," Lebowitz says. So that turmeric latte you've been drinking everyday has no additional brain benefits compared to a regular cup of java.
See Melatonin for information on effects & cost; I regularly use melatonin to sleep (more to induce sleep than prolong or deepen it), and investigating with my Zeo, it does seem to improve & shorten my sleep. Some research suggests that higher doses are not necessarily better and may be overkill, so each time I’ve run out, I’ve been steadily decreasing the dose from 3mg to 1.5mg to 1mg, without apparently compromising the usefulness.
“Cavin has done an amazing job in all aspects of his life. Overcoming the horrific life threatening accident, and then going on to do whatever he can to help others with his contagious wonderful attitude. This book is an easy to understand fact filled manual for anyone, but especially those who are or are caregivers for a loved one with tbi. I also highly recommend his podcast series.”
Starting from the studies in my meta-analysis, we can try to estimate an upper bound on how big any effect would be, if it actually existed. One of the most promising null results, Southon et al 1994, turns out to be not very informative: if we punch in the number of kids, we find that they needed a large effect size (d=0.81) before they could see anything:
Chocolate or cocoa powder (, contains the stimulants caffeine and the caffeine metabolite theobromine, so it’s not necessarily surprising if cocoa powder was a weak stimulant. It’s also a witch’s brew of chemicals such as polyphenols and flavonoids some of which have been fingered as helpful10, which all adds up to an unclear impact on health (once you control for eating a lot of sugar).

In contrast to the types of memory discussed in the previous section, which are long-lasting and formed as a result of learning, working memory is a temporary store of information. Working memory has been studied extensively by cognitive psychologists and cognitive neuroscientists because of its role in executive function. It has been likened to an internal scratch pad; by holding information in working memory, one keeps it available to consult and manipulate in the service of performing tasks as diverse as parsing a sentence and planning a route through the environment. Presumably for this reason, working memory ability correlates with measures of general intelligence (Friedman et al., 2006). The possibility of enhancing working memory ability is therefore of potential real-world interest.
Nootroo and Nootrobox are two San Francisco nootropics startups that launched last year. Their founders come from the tech scene and their products are squarely aimed at the tech crowd seeking the convenience of not having to build their own combinations. Each claims big-name Silicon Valley entrepreneurs and investors among their users, though neither will name them.
Regarding other methods of cognitive enhancement, little systematic research has been done on their prevalence among healthy people for the purpose of cognitive enhancement. One exploratory survey found evidence of modafinil use by people seeking cognitive enhancement (Maher, 2008), and anecdotal reports of this can be found online (e.g., Arrington, 2008; Madrigal, 2008). Whereas TMS requires expensive equipment, tDCS can be implemented with inexpensive and widely available materials, and online chatter indicates that some are experimenting with this method.

Running low on gum (even using it weekly or less, it still runs out), I decided to try patches. Reading through various discussions, I couldn’t find any clear verdict on what patch brands might be safer (in terms of nicotine evaporation through a cut or edge) than others, so I went with the cheapest Habitrol I could find as a first try of patches (Nicotine Transdermal System Patch, Stop Smoking Aid, 21 mg, Step 1, 14 patches) in May 2013. I am curious to what extent nicotine might improve a long time period like several hours or a whole day, compared to the shorter-acting nicotine gum which feels like it helps for an hour at most and then tapers off (which is very useful in its own right for kicking me into starting something I have been procrastinating on). I have not decided whether to try another self-experiment.

Because these drugs modulate important neurotransmitter systems such as dopamine and noradrenaline, users take significant risks with unregulated use. There has not yet been any definitive research into modafinil's addictive potential, how its effects might change with prolonged sleep deprivation, or what side effects are likely at doses outside the prescribed range.
11:30 AM. By 2:30 PM, my hunger is quite strong and I don’t feel especially focused - it’s difficult to get through the tab-explosion of the morning, although one particularly stupid poster on the DNB ML makes me feel irritated like I might on Adderall. I initially figure the probability at perhaps 60% for Adderall, but when I wake up at 2 AM and am completely unable to get back to sleep, eventually racking up a Zeo score of 73 (compared to the usual 100s), there’s no doubt in my mind (95%) that the pill was Adderall. And it was the last Adderall pill indeed.
Googling, you sometimes see correlational studies like Intake of Flavonoid-Rich Wine, Tea, and Chocolate by Elderly Men and Women Is Associated with Better Cognitive Test Performance; in this one, the correlated performance increase from eating chocolate was generally fairly modest (say, <10%), and the maximum effects were at 10g/day of what was probably milk chocolate, which generally has 10-40% chocolate liquor in it, suggesting any experiment use 1-4g. More interesting is the blind RCT experiment Consumption of cocoa flavanols results in acute improvements in mood and cognitive performance during sustained mental effort11, which found improvements at ~1g; the most dramatic improvement of the 4 tasks (on the Threes correct) saw a difference of 2 to 6 at the end of the hour of testing, while several of the other tests converged by the end or saw the controls winning (Sevens correct). Crews et al 2008 found no cognitive benefit, and an fMRI experiment found the change in brain oxygen levels it wanted but no improvement to reaction times.
Exercise and nutrition also play an important role in neuroplasticity. Many vitamins and ingredients found naturally in food products have been shown to have cognitive enhancing effects. Some of these include vitamins B6 and B12, caffeine, phenethylamine found in chocolate and l-theanine, found in green tea, whose combined effects with caffeine are more extensively researched.
Two studies investigated the effects of MPH on reversal learning in simple two-choice tasks (Clatworthy et al., 2009; Dodds et al., 2008). In these tasks, participants begin by choosing one of two stimuli and, after repeated trials with these stimuli, learn that one is usually rewarded and the other is usually not. The rewarded and nonrewarded stimuli are then reversed, and participants must then learn to choose the new rewarded stimulus. Although each of these studies found functional neuroimaging correlates of the effects of MPH on task-related brain activity (increased blood oxygenation level-dependent signal in frontal and striatal regions associated with task performance found by Dodds et al., 2008, using fMRI and increased dopamine release in the striatum as measured by increased raclopride displacement by Clatworthy et al., 2009, using PET), neither found reliable effects on behavioral performance in these tasks. The one significant result concerning purely behavioral measures was Clatworthy et al.’s (2009) finding that participants who scored higher on a self-report personality measure of impulsivity showed more performance enhancement with MPH. MPH’s effect on performance in individuals was also related to its effects on individuals’ dopamine activity in specific regions of the caudate nucleus.
The evidence? Ritalin is FDA-approved to treat ADHD. It has also been shown to help patients with traumatic brain injury concentrate for longer periods, but does not improve memory in those patients, according to a 2016 meta-analysis of several trials. A study published in 2012 found that low doses of methylphenidate improved cognitive performance, including working memory, in healthy adult volunteers, but high doses impaired cognitive performance and a person’s ability to focus. (Since the brains of teens have been found to be more sensitive to the drug’s effect, it’s possible that methylphenidate in lower doses could have adverse effects on working memory and cognitive functions.)
Despite decades of study, a full picture has yet to emerge of the cognitive effects of the classic psychostimulants and modafinil. Part of the problem is that getting rats, or indeed students, to do puzzles in laboratories may not be a reliable guide to the drugs’ effects in the wider world. Drugs have complicated effects on individuals living complicated lives. Determining that methylphenidate enhances cognition in rats by acting on their prefrontal cortex doesn’t tell you the potential impact that its effects on mood or motivation may have on human cognition.
No. There are mission essential jobs that require you to live on base sometimes. Or a first term person that is required to live on base. Or if you have proven to not be as responsible with rent off base as you should be so your commander requires you to live on base. Or you’re at an installation that requires you to live on base during your stay. Or the only affordable housing off base puts you an hour away from where you work. It isn’t simple. The fact that you think it is tells me you are one of the “dumb@$$es” you are referring to above.
A 100mg dose of caffeine (half of a No-Doz or one cup of strong coffee) with 200mg of L-theanine is what the nootropics subreddit recommends in their beginner’s FAQ, and many nootropic sellers, like Peak Nootropics, suggest the same. In my own experiments, I used a pre-packaged combination from Nootrobox called Go Cubes. They’re essentially chewable coffee cubes (not as gross as it sounds) filled with that same beginner dose of caffeine, L-theanine, as well as a few B vitamins thrown into the mix. After eating an entire box of them (12 separate servings—not all at once), I can say eating them made me feel more alert and energetic, but less jittery than my usual three cups of coffee every day. I noticed enough of a difference in the past two weeks that I’ll be looking into getting some L-theanine supplements to take with my daily coffee.

The information learned in the tasks reviewed so far was explicit, declarative, and consistent within each experiment. In contrast, probabilistic and procedural learning tasks require the subject to gradually extract a regularity in the associations among stimuli from multiple presentations in which the correct associations are only presented some of the time, with incorrect associations also presented. Findings are mixed in these tasks. Breitenstein and colleagues (2004, 2006) showed subjects drawings of common objects accompanied by nonsense word sounds in training sessions that extended over multiple days. They found faster learning of the to-be-learned, higher probability pairings between sessions (consistent with enhanced retention over longer delays). Breitenstein et al. (2004) found that this enhancement remained a year later. Schlösser et al. (2009) tested subjects’ probabilistic learning ability in the context of a functional magnetic resonance imaging (fMRI) study, comparing performance and brain activation with MPH and placebo. MPH did not affect learning performance as measured by accuracy. Although subjects were overall faster in responding on MPH, this difference was independent of the difficulty of the learning task, and the authors accordingly attributed it to response processes rather than learning.

Finally, all of the questions raised here in relation to MPH and d-AMP can also be asked about newer drugs and even about nonpharmacological methods of cognitive enhancement. An example of a newer drug with cognitive-enhancing potential is modafinil. Originally marketed as a therapy for narcolepsy, it is widely used off label for other purposes (Vastag, 2004), and a limited literature on its cognitive effects suggests some promise as a cognitive enhancer for normal healthy people (see Minzenberg & Carter, 2008, for a review).
When taken as prescribed, Modafinil is safer than Adderall with fewer side effects. Smart pill enthusiasts find a heightened sense of alertness and motivation with Modafinil. In healthy individuals, Modafinil will reliably boost energy levels. If you find that it gives you headaches, add a choline supplement to your stack. With that said, you should only use Modafinil in moderation on an as-needed basis.

One curious thing that leaps out looking at the graphs is that the estimated underlying standard deviations differ: the nicotine days have a strikingly large standard deviation, indicating greater variability in scores - both higher and lower, since the means weren’t very different. The difference in standard deviations is just 6.6% below 0, so the difference almost reaches our usual frequentist levels of confidence too, which we can verify by testing:
There are certain risks associated with smart pills that might restrain their use. A smart pill usually leaves the body within two weeks. Sometimes, the pill might get lodged in the digestive tract rather than exiting the body via normal bowel movements. The risk might be higher in people with a tumor, Crohns disease, or some surgery within that area that lead to narrowing of the digestive tract. CT scan is usually performed in people with high-risk to assess the narrowing of the tract. However, the pill might still be lodged even if the results are negative for the CT scan, which might lead to bowel obstruction and can be removed either by surgery or traditional endoscopy. Smart pills might lead to skin irritation, which results in mild redness and need to be treated topically. It may also lead to capsule aspiration, which involves the capsule going down the wrong pipe and entering the airway instead of the esophagus. This might result in choking and death if immediate bronchoscopic extraction is not performed. Patients with comorbidities related to brain injury or chronic obstructive pulmonary disease may be at a higher risk. So, the health risks associated with the use of smart pills are hindering the smart pills technology market. The other factors, such as increasing cost with technological advancement and ethical constraints are also hindering the market.

After I ran out of creatine, I noticed the increased difficulty, and resolved to buy it again at some point; many months later, there was a Smart Powders sale so bought it in my batch order, $12 for 1000g. As before, it made Taekwondo classes a bit easier. I paid closer attention this second time around and noticed that as one would expect, it only helped with muscular fatigue and did nothing for my aerobic issues. (I hate aerobic exercise, so it’s always been a weak point.) I eventually capped it as part of a sulbutiamine-DMAE-creatine-theanine mix. This ran out 1 May 2013. In March 2014, I spent $19 for 1kg of micronized creatine monohydrate to resume creatine use and also to use it as a placebo in a honey-sleep experiment testing Seth Roberts’s claim that a few grams of honey before bedtime would improve sleep quality: my usual flour placebo being unusable because the mechanism might be through simple sugars, which flour would digest into. (I did not do the experiment: it was going to be a fair amount of messy work capping the honey and creatine, and I didn’t believe Roberts’s claims for a second - my only reason to do it would be to prove the claim wrong but he’d just ignore me and no one else cares.) I didn’t try measuring out exact doses but just put a spoonful in my tea each morning (creatine is tasteless). The 1kg lasted from 25 March to 18 September or 178 days, so ~5.6g & $0.11 per day.
Taurine ( was another gamble on my part, based mostly on its inclusion in energy drinks. I didn’t do as much research as I should have: it came as a shock to me when I read in Wikipedia that taurine has been shown to prevent oxidative stress induced by exercise and was an antioxidant - oxidative stress is a key part of how exercise creates health benefits and antioxidants inhibit those benefits.
Still, the scientific backing and ingredient sourcing of nootropics on the market varies widely, and even those based in some research won't necessarily immediately, always or ever translate to better grades or an ability to finally crank out that novel. Nor are supplements of any kind risk-free, says Jocelyn Kerl, a pharmacist in Madison, Wisconsin.
Of all the smart drugs in the world, Modafinil is most often touted as the best. It’s a powerful cognitive enhancer, great for boosting alertness, and has very few, mild side effects that most healthy users will never experience. And no, you can’t have any. Sorry. Modafinil is a prescription medication used to treat disorders like narcolepsy, shift work sleep disorder, and for those who suffer from obstructive sleep apnea.
At dose #9, I’ve decided to give up on kratom. It is possible that it is helping me in some way that careful testing (eg. dual n-back over weeks) would reveal, but I don’t have a strong belief that kratom would help me (I seem to benefit more from stimulants, and I’m not clear on how an opiate-bearer like kratom could stimulate me). So I have no reason to do careful testing. Oh well.
If you have spent any time shopping for memory enhancer pills, you have noticed dozens of products on the market. Each product is advertised to improve memory, concentration, and focus. However, choosing the first product promising results may not produce the desired improvements. Taking the time to research your options and compare products will improve your chances of finding a supplement that works.
A “smart pill” is a drug that increases the cognitive ability of anyone taking it, whether the user is cognitively impaired or normal. The Romanian neuroscientist Corneliu Giurgea is often credited with first proposing, in the 1960s, that smart pills should be developed to increase the intelligence of the general population (see Giurgea, 1984). He is quoted as saying, “Man is not going to wait passively for millions of years before evolution offers him a better brain” (Gazzaniga, 2005, p. 71). In their best-selling book, Smart Drugs and Nutrients, Dean and Morgenthaler (1990) reviewed a large number of substances that have been used by healthy individuals with the goal of increasing cognitive ability. These include synthetic and natural products that affect neurotransmitter levels, neurogenesis, and blood flow to the brain. Although many of these substances have their adherents, none have become widely used. Caffeine and nicotine may be exceptions to this generalization, as one motivation among many for their use is cognitive enhancement (Julien, 2001).
In addition, while the laboratory research reviewed here is of interest concerning the effects of stimulant drugs on specific cognitive processes, it does not tell us about the effects on cognition in the real world. How do these drugs affect academic performance when used by students? How do they affect the total knowledge and understanding that students take with them from a course? How do they affect various aspects of occupational performance? Similar questions have been addressed in relation to students and workers with ADHD (Barbaresi, Katusic, Colligan, Weaver, & Jacobsen, 2007; Halmøy, Fasmer, Gillberg, & Haavik, 2009; see also Advokat, 2010) but have yet to be addressed in the context of cognitive enhancement of normal individuals.
The choline-based class of smart drugs play important cognitive roles in memory, attention, and mood regulation. Acetylcholine (ACh) is one of the brain’s primary neurotransmitters, and also vital in the proper functioning of the peripheral nervous system. Studies with rats have shown that certain forms of learning and neural plasticity seem to be impossible in acetylcholine-depleted areas of the brain. This is particularly worth mentioning because (as noted above under the Racetams section), the Racetam class of smart drugs tends to deplete cholines from the brain, so one of the classic “supplement stacks” – chemical supplements that are used together – are Piracetam and Choline Bitartrate. Cholines can also be found in normal food sources, like egg yolks and soybeans.
“Cavin has done an amazing job in all aspects of his life. Overcoming the horrific life threatening accident, and then going on to do whatever he can to help others with his contagious wonderful attitude. This book is an easy to understand fact filled manual for anyone, but especially those who are or are caregivers for a loved one with tbi. I also highly recommend his podcast series.”
(People aged <=18 shouldn’t be using any of this except harmless stuff - where one may have nutritional deficits - like fish oil & vitamin D; melatonin may be especially useful, thanks to the effects of screwed-up school schedules & electronics use on teenagers’ sleep. Changes in effects with age are real - amphetamines’ stimulant effects and modafinil’s histamine-like side-effects come to mind as examples.)
I posted a link to the survey on my Google+ account, and inserted the link at the top of all pages; 51 people completed all 11 binary choices (most of them coming from North America & Europe), which seems adequate since the 11 questions are all asking the same question, and 561 responses to one question is quite a few. A few different statistical tests seem applicable: a chi-squared test whether there’s a difference between all the answers, a two-sample test on the averages, and most meaningfully, summing up the responses as a single pair of numbers and doing a binomial test:
"Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. [...] Accordingly, these products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling."[33]