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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.
Vitamin B12 is also known as Cobalamin and is a water-soluble essential vitamin.  A (large) deficiency of Vitamin B12 will ultimately lead to cognitive impairment [52]. Older people and people who don’t eat meat are at a higher risk than young people who eat more meat. And people with depression have less Vitamin B12 than the average population [53].
Vitamin B12 is also known as Cobalamin and is a water-soluble essential vitamin.  A (large) deficiency of Vitamin B12 will ultimately lead to cognitive impairment [52]. Older people and people who don’t eat meat are at a higher risk than young people who eat more meat. And people with depression have less Vitamin B12 than the average population [53].
20 March, 2x 13mg; first time, took around 11:30AM, half-life 3 hours, so halved by 2:30PM. Initial reaction: within 20 minutes, started to feel light-headed, experienced a bit of physical clumsiness while baking bread (dropped things or poured too much thrice); that began to pass in an hour, leaving what felt like a cheerier mood and less anxiety. Seems like it mostly wore off by 6PM. Redosed at 8PM TODO: maybe take a look at the HRV data? looks interestingly like HRV increased thanks to the tianeptine 21 March, 2x17mg; seemed to buffer effects of FBI visit 22 March, 2x 23 March, 2x 24 March, 2x 25 March, 2x 26 March, 2x 27 March, 2x 28 March, 2x 7 April, 2x 8 April, 2x 9 April, 2x 10 April, 2x 11 April, 2x 12 April, 2x 23 April, 2x 24 April, 2x 25 April, 2x 26 April, 2x 27 April, 2x 28 April, 2x 29 April, 2x 7 May, 2x 8 May, 2x 9 May, 2x 10 May, 2x 3 June, 2x 4 June, 2x 5 June, 2x 30 June, 2x 30 July, 1x 31 July, 1x 1 August, 2x 2 August, 2x 3 August, 2x 5 August, 2x 6 August, 2x 8 August, 2x 10 August, 2x 12 August: 2x 14 August: 2x 15 August: 2x 16 August: 1x 18 August: 2x 19 August: 2x 21 August: 2x 23 August: 1x 24 August: 1x 25 August: 1x 26 August: 2x 27 August: 1x 29 August: 2x 30 August: 1x 02 September: 1x 04 September: 1x 07 September: 2x 20 September: 1x 21 September: 2x 24 September: 2x 25 September: 2x 26 September: 2x 28 September: 2x 29 September: 2x 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“One of my favorites is 1, 3, 7-trimethylxanthine,” says Dr. Mark Moyad, director of preventive and alternative medicine at the University of Michigan. He says this chemical boosts many aspects of cognition by improving alertness. It’s also associated with some memory benefits. “Of course,” Moyad says, “1, 3, 7-trimethylxanthine goes by another name—caffeine.”
Minnesota-based Medtronic offers a U.S. Food and Drug Administration (FDA)-cleared smart pill called PillCam COLON, which provides clear visualization of the colon and is complementary to colonoscopy. It is an alternative for patients who refuse invasive colon exams, have bleeding or sedation risks or inflammatory bowel disease, or have had a previous incomplete colonoscopy. PillCam COLON allows  more  people  to  get  screened  for  colorectal  cancer with  a  minimally  invasive, radiation-free option. The research focus for WCEs is on effective localization, steering and control of capsules. Device development relies on leveraging applied science and technologies for better system performance, rather than completely reengineering the pill.
The above are all reasons to expect that even if I do excellent single-subject design self-experiments, there will still be the old problem of internal validity versus external validity: an experiment may be wrong or erroneous or unlucky in some way (lack of internal validity) or be right but not matter to anyone else (lack of external validity). For example, alcohol makes me sad & depressed; I could run the perfect blind randomized experiment for hundreds of trials and be extremely sure that alcohol makes me less happy, but would that prove that alcohol makes everyone sad or unhappy? Of course not, and as far as I know, for a lot of people alcohol has the opposite effect. So my hypothetical alcohol experiment might have tremendous internal validity (it does prove that I am sadder after inebriating), and zero external validity (someone who has never tried alcohol learns nothing about whether they will be depressed after imbibing). Keep this in mind if you are minded to take the experiments too seriously.

More photos from this reportage are featured in Quartz’s new book The Objects that Power the Global Economy. You may not have seen these objects before, but they’ve already changed the way you live. Each chapter examines an object that is driving radical change in the global economy. This is from the chapter on the drug modafinil, which explores modifying the mind for a more productive life. 
The evidence? A 2012 study in Greece found it can boost cognitive function in adults with mild cognitive impairment (MCI), a type of disorder marked by forgetfulness and problems with language, judgement, or planning that are more severe than average “senior moments,” but are not serious enough to be diagnosed as dementia. In some people, MCI will progress into dementia.
…Phenethylamine is intrinsically a stimulant, although it doesn’t last long enough to express this property. In other words, it is rapidly and completely destroyed in the human body. It is only when a number of substituent groups are placed here or there on the molecule that this metabolic fate is avoided and pharmacological activity becomes apparent.
As I am not any of the latter, I didn’t really expect a mental benefit. As it happens, I observed nothing. What surprised me was something I had forgotten about: its physical benefits. My performance in Taekwondo classes suddenly improved - specifically, my endurance increased substantially. Before, classes had left me nearly prostrate at the end, but after, I was weary yet fairly alert and happy. (I have done Taekwondo since I was 7, and I have a pretty good sense of what is and is not normal performance for my body. This was not anything as simple as failing to notice increasing fitness or something.) This was driven home to me one day when in a flurry before class, I prepared my customary tea with piracetam, choline & creatine; by the middle of the class, I was feeling faint & tired, had to take a break, and suddenly, thunderstruck, realized that I had absentmindedly forgot to actually drink it! This made me a believer.
Another class of substances with the potential to enhance cognition in normal healthy individuals is the class of prescription stimulants used to treat attention-deficit/hyperactivity disorder (ADHD). These include methylphenidate (MPH), best known as Ritalin or Concerta, and amphetamine (AMP), most widely prescribed as mixed AMP salts consisting primarily of dextroamphetamine (d-AMP), known by the trade name Adderall. These medications have become familiar to the general public because of the growing rates of diagnosis of ADHD children and adults (Froehlich et al., 2007; Sankaranarayanan, Puumala, & Kratochvil, 2006) and the recognition that these medications are effective for treating ADHD (MTA Cooperative Group, 1999; Swanson et al., 2008).
Another ingredient used in this formula is GABA or Gamma-Aminobutyric acid; it’s the second most common neurotransmitter found in the human brain. Being an inhibitory neurotransmitter it helps calm and reduce neuronal activity; this calming effect makes GABA an excellent ingredient in anti-anxiety medication. Lecithin is another ingredient found in Smart Pill and is a basic compound found in every cell of the body, with cardiovascular benefits it can also help restore the liver. Another effect is that it works with neurological functions such as memory or attention, thus improving brain Effectiveness.
Somewhat ironically given the stereotypes, while I was in college I dabbled very little in nootropics, sticking to melatonin and tea. Since then I have come to find nootropics useful, and intellectually interesting: they shed light on issues in philosophy of biology & evolution, argue against naive psychological dualism and for materialism, offer cases in point on the history of technology & civilization or recent psychology theories about addiction & willpower, challenge our understanding of the validity of statistics and psychology - where they don’t offer nifty little problems in statistics and economics themselves, and are excellent fodder for the young Quantified Self movement4; modafinil itself demonstrates the little-known fact that sleep has no accepted evolutionary explanation. (The hard drugs also have more ramifications than one might expect: how can one understand the history of Southeast Asia and the Vietnamese War without reference to heroin, or more contemporaneously, how can one understand the lasting appeal of the Taliban in Afghanistan and the unpopularity & corruption of the central government without reference to the Taliban’s frequent anti-drug campaigns or the drug-funded warlords of the Northern Alliance?)
We have established strict criteria for reviewing brain enhancement supplements. Our reviews are clear, detailed, and informative to help you find supplements that deliver the best results. You can read our reviews, learn about the best nootropic ingredients, compare formulas, and find out how each supplement performed according to specific criteria.
But like any other supplement, there are some safety concerns negative studies like Fish oil fails to hold off heart arrhythmia or other reports cast doubt on a protective effect against dementia or Fish Oil Use in Pregnancy Didn’t Make Babies Smart (WSJ) (an early promise but one that faded a bit later) or …Supplementation with DHA compared with placebo did not slow the rate of cognitive and functional decline in patients with mild to moderate Alzheimer disease..

 One symptom of Alzheimer's disease is a reduced brain level of the neurotransmitter called acetylcholine. It is thought that an effective treatment for Alzheimer's disease might be to increase brain levels of acetylcholine. Another possible treatment would be to slow the death of neurons that contain acetylcholine. Two drugs, Tacrine and Donepezil, are both inhibitors of the enzyme (acetylcholinesterase) that breaks down acetylcholine. These drugs are approved in the US for treatment of Alzheimer's disease.

Another interpretation of the mixed results in the literature is that, in some cases at least, individual differences in response to stimulants have led to null results when some participants in the sample are in fact enhanced and others are not. This possibility is not inconsistent with the previously mentioned ones; both could be at work. Evidence has already been reviewed that ability level, personality, and COMT genotype modulate the effect of stimulants, although most studies in the literature have not broken their samples down along these dimensions. There may well be other as-yet-unexamined individual characteristics that determine drug response. The equivocal nature of the current literature may reflect a mixture of substantial cognitive-enhancement effects for some individuals, diluted by null effects or even counteracted by impairment in others.


* These statements have not been evaluated by the Food and Drug Administration. The products and information on this website are not intended to diagnose, treat, cure or prevent any disease. The information on this site is for educational purposes only and should not be considered medical advice. Please speak with an appropriate healthcare professional when evaluating any wellness related therapy. Please read the full medical disclaimer before taking any of the products offered on this site.

These days, young, ambitious professionals prefer prescription stimulants—including methylphenidate (usually sold as Ritalin) and Adderall—that are designed to treat people with attention deficit hyperactivity disorder (ADHD) and are more common and more acceptable than cocaine or nicotine (although there is a black market for these pills). ADHD makes people more likely to lose their focus on tasks and to feel restless and impulsive. Diagnoses of the disorder have been rising dramatically over the past few decades—and not just in kids: In 2012, about 16 million Adderall prescriptions were written for adults between the ages of 20 and 39, according to a report in the New York Times. Both methylphenidate and Adderall can improve sustained attention and concentration, says Barbara Sahakian, professor of clinical neuropsychology at the University of Cambridge and author of the 2013 book Bad Moves: How Decision Making Goes Wrong, and the Ethics of Smart Drugs. But the drugs do have side effects, including insomnia, lack of appetite, mood swings, and—in extreme cases—hallucinations, especially when taken in amounts the exceed standard doses. Take a look at these 10 foods that help you focus.


But perhaps the biggest difference between Modafinil and other nootropics like Piracetam, according to Patel, is that Modafinil studies show more efficacy in young, healthy people, not just the elderly or those with cognitive deficits. That’s why it’s great for (and often prescribed to) military members who are on an intense tour, or for those who can’t get enough sleep for physiological reasons. One study, by researchers at Imperial College London, and published in Annals of Surgery, even showed that Modafinil helped sleep-deprived surgeons become better at planning, redirecting their attention, and being less impulsive when making decisions.
Another classic approach to the assessment of working memory is the span task, in which a series of items is presented to the subject for repetition, transcription, or recognition. The longest series that can be reproduced accurately is called the forward span and is a measure of working memory capacity. The ability to reproduce the series in reverse order is tested in backward span tasks and is a more stringent test of working memory capacity and perhaps other working memory functions as well. The digit span task from the Wechsler (1981) IQ test was used in four studies of stimulant effects on working memory. One study showed that d-AMP increased digit span (de Wit et al., 2002), and three found no effects of d-AMP or MPH (Oken, Kishiyama, & Salinsky, 1995; Schmedtje, Oman, Letz, & Baker, 1988; Silber, Croft, Papafotiou, & Stough, 2006). A spatial span task, in which subjects must retain and reproduce the order in which boxes in a scattered spatial arrangement change color, was used by Elliott et al. (1997) to assess the effects of MPH on working memory. For subjects in the group receiving placebo first, MPH increased spatial span. However, for the subjects who received MPH first, there was a nonsignificant opposite trend. The group difference in drug effect is not easily explained. The authors noted that the subjects in the first group performed at an overall lower level, and so, this may be another manifestation of the trend for a larger enhancement effect for less able subjects.
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.
Some people aren’t satisfied with a single supplement—the most devoted self-improvers buy a variety of different compounds online and create their own custom regimens, which they call “stacks.” According to Kaleigh Rogers, writing in Vice last year, companies will now take their customers’ genetic data from 23andMe or another source and use it to recommend the right combinations of smart drugs to optimize each individual’s abilities. The problem with this practice is that there’s no evidence the practice works. (And remember, the FDA doesn’t regulate supplements.) Find out the 9 best foods to boost your brain health.
“I bought this book because I didn’t want a weightloss diet, but I wanted the most optimal gut/brain food I could find to help with an autoimmune. I subscribe to Cavin’s podcast and another newsletter for gut health which also recommended this book. Also, he’s a personal friend of mine who’s recovery I have witnessed firsthand. Thank you so much for all of the research and your continued dedication to not only help yourself, but for also helping others!”
Of course, there are drugs out there with more transformative powers. “I think it’s very clear that some do work,” says Andrew Huberman, a neuroscientist based at Stanford University. In fact, there’s one category of smart drugs which has received more attention from scientists and biohackers – those looking to alter their own biology and abilities – than any other. These are the stimulants.
Nootropics are a responsible way of using smart drugs to enhance productivity. As defined by Giurgea in the 1960’s, nootropics should have little to no side-effects. With nootropics, there should be no dependency. And maybe the effects of nootropics are smaller than for instance Adderall, you still improve your productivity without risking your life. This is what separates nootropics from other drugs.
On 8 April 2011, I purchased from Smart Powders (20g for $8); as before, some light searching seemed to turn up SP as the best seller given shipping overhead; it was on sale and I planned to cap it so I got 80g. This may seem like a lot, but I was highly confident that theanine and I would get along since I already drink so much tea and was a tad annoyed at the edge I got with straight caffeine. So far I’m pretty happy with it. My goal was to eliminate the physical & mental twitchiness of caffeine, which subjectively it seems to do.

The Nootroo arrives in a shiny gold envelope with the words “proprietary blend” and “intended for use only in neuroscience research” written on the tin. It has been designed, says Matzner, for “hours of enhanced learning and memory”. The capsules contain either Phenylpiracetam or Noopept (a peptide with similar effects and similarly uncategorised) and are distinguished by real flakes of either edible silver or gold. They are to be alternated between daily, allowing about two weeks for the full effect to be felt. Also in the capsules are L-Theanine, a form of choline, and a types of caffeine which it is claimed has longer lasting effects.
It may also be necessary to ask not just whether a drug enhances cognition, but in whom. Researchers at the University of Sussex have found that nicotine improved performance on memory tests in young adults who carried one variant of a particular gene but not in those with a different version. In addition, there are already hints that the smarter you are, the less smart drugs will do for you. One study found that modafinil improved performance in a group of students whose mean IQ was 106, but not in a group with an average of 115.

A record of nootropics I have tried, with thoughts about which ones worked and did not work for me. These anecdotes should be considered only as anecdotes, and one’s efforts with nootropics a hobby to put only limited amounts of time into due to the inherent limits of drugs as a force-multiplier compared to other things like programming1; for an ironic counterpoint, I suggest the reader listen to a video of Jonathan Coulton’s I Feel Fantastic while reading.


One should note the serious caveats here: it is a small in vitro study of a single category of human cells with an effect size that is not clear on a protein which feeds into who-knows-what pathways. It is not a result in a whole organism on any clinically meaningful endpoint, even if we take it at face-value (many results never replicate). A look at followup work citing Rapuri et al 2007 is not encouraging: Google Scholar lists no human studies of any kind, much less high-quality studies like RCTs; just some rat followups on the calcium effect. This is not to say Rapuri et al 2007 is a bad study, just that it doesn’t bear the weight people are putting on it: if you enjoy caffeine, this is close to zero evidence that you should reduce or drop caffeine consumption; if you’re taking too much caffeine, you already have plenty of reasons to reduce; if you’re drinking lots of coffee, you already have plenty of reasons to switch to tea; etc.
Remembering what Wedrifid told me, I decided to start with a quarter of a piece (~1mg). The gum was pretty tasteless, which ought to make blinding easier. The effects were noticeable around 10 minutes - greater energy verging on jitteriness, much faster typing, and apparent general quickening of thought. Like a more pleasant caffeine. While testing my typing speed in Amphetype, my speed seemed to go up >=5 WPM, even after the time penalties for correcting the increased mistakes; I also did twice the usual number without feeling especially tired. A second dose was similar, and the third dose was at 10 PM before playing Ninja Gaiden II seemed to stop the usual exhaustion I feel after playing through a level or so. (It’s a tough game, which I have yet to master like Ninja Gaiden Black.) Returning to the previous concern about sleep problems, though I went to bed at 11:45 PM, it still took 28 minutes to fall sleep (compared to my more usual 10-20 minute range); the next day I use 2mg from 7-8PM while driving, going to bed at midnight, where my sleep latency is a more reasonable 14 minutes. I then skipped for 3 days to see whether any cravings would pop up (they didn’t). I subsequently used 1mg every few days for driving or Ninja Gaiden II, and while there were no cravings or other side-effects, the stimulation definitely seemed to get weaker - benefits seemed to still exist, but I could no longer describe any considerable energy or jitteriness.
It can easily pass through the blood-brain barrier and is known to protect the nerve tissues present in the brain. There is evidence that the acid plays an instrumental role in preventing strokes in adults by decreasing the number of free radicals in the body.  It increases the production of acetylcholine, a neurotransmitter that most Alzheimer’s patients are a deficit in.
I have no particularly compelling story for why this might be a correlation and not causation. It could be placebo, but I wasn’t expecting that. It could be selection effect (days on which I bothered to use the annoying LED set are better days) but then I’d expect the off-days to be below-average and compared to the 2 years of trendline before, there doesn’t seem like much of a fall.
This tendency is exacerbated by general inefficiencies in the nootropics market - they are manufactured for vastly less than they sell for, although the margins aren’t as high as they are in other supplement markets, and not nearly as comical as illegal recreational drugs. (Global Price Fixing: Our Customers are the Enemy (Connor 2001) briefly covers the vitamin cartel that operated for most of the 20th century, forcing food-grade vitamins prices up to well over 100x the manufacturing cost.) For example, the notorious Timothy Ferriss (of The Four-hour Work Week) advises imitators to find a niche market with very high margins which they can insert themselves into as middlemen and reap the profits; one of his first businesses specialized in… nootropics & bodybuilding. Or, when Smart Powders - usually one of the cheapest suppliers - was dumping its piracetam in a fire sale of half-off after the FDA warning, its owner mentioned on forums that the piracetam was still profitable (and that he didn’t really care because selling to bodybuilders was so lucrative); this was because while SP was selling 2kg of piracetam for ~$90, Chinese suppliers were offering piracetam on AliBaba for $30 a kilogram or a third of that in bulk. (Of course, you need to order in quantities like 30kg - this is more or less the only problem the middlemen retailers solve.) It goes without saying that premixed pills or products are even more expensive than the powders.
Some critics argue that Modafinil is an expression of that, a symptom of a new 24/7 work routine. But what if the opposite is true? Let’s say you could perform a task in significantly less time than usual. You could then use the rest of your time differently, spending it with family, volunteering, or taking part in a leisure activity. And imagine that a drug helped you focus on clearing your desk and inbox before leaving work. Wouldn’t that help you relax once you get home?
The main area of the brain effected by smart pills is the prefrontal cortex, where representations of our goals for the future are created. Namely, the prefrontal cortex consists of pyramidal cells that keep each other firing. However in some instances they can become disconnected due to chemical imbalances, or due to being tired, stressed, and overworked.

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Also known as Arcalion or Bisbuthiamine and Enerion, Sulbutiamine is a compound of the Sulphur group and is an analog to vitamin B1, which is known to pass the blood-brain barrier easily. Sulbutiamine is found to circulate faster than Thiamine from blood to brain. It is recommended for patients suffering from mental fatigue caused due to emotional and psychological stress. The best part about this compound is that it does not have most of the common side effects linked with a few nootropics.


“We stumbled upon fasting as a way to optimize cognition and make yourself into a more efficient human being,” says Manuel Lam, an internal medicine physician who advises Nootrobox on clinical issues. He and members of the company’s executive team have implanted glucose monitors in their arms — not because they fear diabetes but because they wish to track the real-time effect of the foods they eat.
If you haven’t seen the movie, imagine unfathomable brain power in capsule form. Picture a drug from another universe. It can transform an unsuccessful couch potato into a millionaire financial mogul. Ingesting the powerful smart pill boosts intelligence and turns you into a prodigy. Its results are instant. Sounds great, right? If only it were real.
Nature magazine conducted a poll asking its readers about their cognitive-enhancement practices and their attitudes toward cognitive enhancement. Hundreds of college faculty and other professionals responded, and approximately one fifth reported using drugs for cognitive enhancement, with Ritalin being the most frequently named (Maher, 2008). However, the nature of the sample—readers choosing to answer a poll on cognitive enhancement—is not representative of the academic or general population, making the results of the poll difficult to interpret. By analogy, a poll on Vermont vacations, asking whether people vacation in Vermont, what they think about Vermont, and what they do if and when they visit, would undoubtedly not yield an accurate estimate of the fraction of the population that takes its vacations in Vermont.
the rise of IP scofflaw countries which enable the manufacture of known drugs: India does not respect the modafinil patents, enabling the cheap generics we all use, and Chinese piracetam manufacturers don’t give a damn about the FDA’s chilling-effect moves in the US. If there were no Indian or Chinese manufacturers, where would we get our modafinil? Buy them from pharmacies at $10 a pill or worse? It might be worthwhile, but think of the chilling effect on new users.
A quick search for drugs that make you smarter will lead you to the discovery of piracetam. Piracetam is the first synthetic smart drug of its kind. All other racetams derive from Piracetam. Some are far more potent, but they may also carry more side effects. Piracetam is an allosteric modulator of acetylcholine receptors. In other words, it enhances acetylcholine synthesis which boosts cognitive function.
Proteus Digital Health (Redwood City, Calif.) offers an FDA-approved microchip—an ingestible pill that tracks medication-taking behavior and how the body is responding to medicine. Through the company’s Digital Health Feedback System, the sensor monitors blood flow, body temperature and other vital signs for people with heart problems, schizophrenia or Alzheimer’s disease.
"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]
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