Our partnership with Frothly

An optical implant is a computer that sits between a person and everything they see. Somebody independent ought to be able to look inside it.

Kiroshi Opticals, the company our founder started as a lens workshop in 1952, now makes cybernetic eyes and retinal implants used by about 3.4 million people. The software in them decides what to sharpen, what to label and what to leave out. For people who were blind, that software is the difference between a doorway and a wall. For everyone who wears one, it is a set of choices made on their behalf by a company in which the Foundation is the largest shareholder.

We could not credibly check that software ourselves, and we did not want to pretend we could. Frothly has spent four decades studying what happens to public life when machines decide on our behalf. It holds no shares, sells no products and publishes what it finds. In 2021 we asked whether it would work with us, on its terms.

Blackwall is Frothly’s programme of independent evaluations of AI systems before they are deployed. Laboratories submit voluntarily, and every evaluation ends in a public report, including findings the laboratory would rather were not published.

In 2023, as Kiroshi Opticals’ largest shareholder, we asked the company to submit its perception models to Blackwall before release. It agreed on 30 October 2023. Since then it has submitted two: SHIKAI 3, the model in implants sold from 2024, and SHIKAI 4, from 2026. That participation, together with this research partnership, is why Kiroshi appears among the institutions listed on Frothly’s home page.

We pay for none of Blackwall’s evaluations of Kiroshi Opticals systems, and we do not see the reports before they are published. When Blackwall’s evaluation of SHIKAI 4 found that the model was markedly less reliable at recognising white canes and guide dog harnesses in low light, we learned of it on the day of publication, along with everyone else. Our statement set out what we asked the company to do next.

The Turing Registry, which Frothly runs from Zürich, is a public record of autonomous systems: who built each one, what it is licensed to do and who answers when something goes wrong. People often ask why Kiroshi Opticals has no filings on it.

The company’s position is that the perception model in its implants is a component of a medical device, which informs its wearer but does not act in the world, and that medical device regulators in the twenty-three countries where it sells implants are the right authorities to oversee it. That position is not unreasonable, and it is not ours to decide.

Our position is that the question deserves a public answer rather than a default. On 12 February 2024 we wrote to the company asking it to keep the matter under review as its implants do more, and published the letter, which is below. We repeated the request in a shareholder statement at the company’s 2025 general meeting. When we wrote KF-OS 2, our standard on bystander privacy, we cited the Registry’s 2023 revocations of TR-08333 and TR-08332, two systems licensed to keep or extract people’s engrams, which lost their licences for doing so without consent. They are the reason the standard forbids an implant to retain images of the people its wearer looks at.