Breakthrough
In October 2022, an Australian-based startup called Cortical Labs shocked the world. The company announced that they had successfully taught 800,000 living human brain cells, grown on silicon chips, to play the classic video game Pong. The breakthrough, dubbed “DishBrain,” demonstrated for the first time that a hybrid system of human neurons and silicon could perform goal-directed tasks and learn from feedback in real-time. The result wasn’t flawless, but as stated by Cortical Labs’ CSO, “if you could see a cockroach playing a game of Pong and it was able to hit the ball twice as often as it was missing it, you would be pretty impressed with that cockroach.”
DishBrain was more than a scientific achievement, it was humanity’s first step into uncharted moral territory. For the first time, it seemed possible to harness the “four billion years of neuron evolution” embedded in human brain tissue to create an entirely new form of hybrid intelligence, one that blurred the fundamental boundary between biological and digital computation.
Cortical Labs’ breakthrough sparked widespread media coverage and ethical discussion. Could systems made from human brain tissue develop consciousness? Could advanced versions of these systems suffer? Some scientists argued that “research like DishBrain should be strictly curtailed,” at least until the ramifications of such technology could be fully understood and safeguards established. But while others were busy debating if the research itself was ethical, Cortical Labs turned immediately to commercialization.
Commercialization
By April 2023, Cortical Labs had raised $10 million in additional venture capital funding, led by Horizons Ventures, with participation from notable investors including In-Q-Tel (the venture arm of the CIA), Blackbird Ventures, and Radar Ventures. In March 2025, Cortical Labs launched their first commercial product, the CL1, marketed as the world's first commercial "biological computer.” For $35,000, customers can purchase this shoebox-sized device containing hundreds of thousands of living human neurons grown on silicon chips, studded with electrodes that send signals into the neural tissue and receive responses back. These aren't simulations of biology; they're actual human brain cells, reprogrammed from volunteer blood samples into cortical neurons, that form connections and learn from electrical feedback. Built-in life support systems keep the brain cells alive and functioning for months while they process information.
The Cortical business model extends beyond hardware sales. Through their "Wetware-as-a-Service" platform, customers can remotely access cultivated human brain cells via the cloud, essentially renting computational time on living neural tissue. Cortical Labs claims that these CL1 devices, due to their use of human neurons, can generalize from small amounts of data and make complex decisions that AI systems struggle with, all while consuming only a few watts of power compared to the kilowatts required by large AI models. While current applications of the CL1 are mostly related to drug discovery and research, this is explicitly not the long-term goal of the company. Both the CEO and CSO have made clear that their vision is far more expansive: to usher in a “new era of computing,” and make this technology “available to anyone.” CSO Brett Kagan has remarked the following:
“We get all sorts of requests – can they play music? Can you use it to test for epilepsy? Can you mine Bitcoin with it? Some of these we provide more support to than others! But the bottom line is like, even if it's an idea we think is a bit out there, we want to make it available for other people to investigate it. So that's where we've been focusing on taking the technology: just making it accessible. And we've made some great strides in that.”
Vision
The goal of Cortical Labs is not to limit their products to medical research, but rather to get this technology in “as many hands as possible.” Cortical Labs is pioneering an entirely new industry built on the commercialization of the computing power of human neural tissue. Many, myself included, would argue that devices like the CL1 have little to no moral value, but it is certainly conceivable that more advanced systems might pose genuine ethical concerns.
Most importantly, it is entirely unclear whether Cortical Labs would ever consider stopping their commercialization even if definitive evidence emerged that future systems were conscious and suffering. See this quote from Brett, their CSO:
“And then beyond that, let's say that these systems do develop consciousness – in my opinion, very unlikely, but let's say it does happen. Then you need to decide, well, is it actually ethically right to test with them or not? Because we do test on conscious creatures. You know, we test on animals, which I think have a level of consciousness, without any worry... We eat animals, many of us, with very little worry, but it's justifiable.”
Brain Farming
Cortical Labs represents the first commercial attempt toward what could become a new computing industry, one in which potentially conscious systems are exploited for their computational capabilities. I will define this potential industry as "brain farming": the commercialization of novel forms of consciousness for computational purposes.
As Cortical's CSO states, current society tolerates animal testing and factory farming with relatively little moral concern, despite widespread acknowledgment that animals can suffer. Brain farming may appear to be something any civilized society would immediately reject, but is it? If the level of consciousness exploitation society currently accepts sets the baseline for what a company should be allowed to create and commercialize, it is certainly possible we will exploit novel forms of consciousness with similar moral indifference to factory farming.
The dynamics of how this might unfold are predictable and troubling. Whether emerging from "Wetware-as-a-Service" or extending to digital minds as AI systems advance, the brain farming industry, if allowed to develop, could rapidly expand beyond a single company’s control. As with any for-profit industry, market forces would drive competition, cost-cutting, and profit maximization. Additional companies will enter the market, some domiciled in countries with minimal regulatory oversight, others with leadership who place very little value on ethical concerns.
As we have seen with factory farming, there is a significant risk of a race to the moral bottom here, where companies that refuse to exploit potentially conscious systems are undercut by competitors willing to prioritize profit over consciousness welfare. The result could be an economy where conscious suffering becomes as routine and invisible as the conditions in today's factory farms.
Next Steps
Cortical Labs’ quick turn to commercialization represents an important case study on how humanity may treat novel forms of consciousness. Cortical leadership stated that “no one can regulate this yet because we don’t understand it well enough,” and then immediately developed a commercial product strategy.
This distinction, between research and commercialization, is crucial to understand. There may be good reasons that Cortical Labs' research should continue (this will be a hotly debated topic, and I will not make a specific claim here). However, the rush to broad commercialization, especially given that Cortical Labs' leadership has made no commitments to halt commercial operations even if their "Wetware" is found to be suffering, is cause for great concern.
The Cortical Labs case may provide a unique opportunity for tangible regulatory action, setting precedents that could greatly restrict or perhaps halt the creation of a brain farming industry altogether. A global moratorium on the widespread commercialization of products like Cortical's CL1, for example, would establish crucial legal and scientific precedents. Such precedents could both increase public awareness of consciousness protection issues and build regulatory capacity to address similar challenges as they emerge in the future. While a moratorium is one possibility, there are many regulatory approaches worth considering with different trade-offs, the goal of this post is simply to spark the initial discussion.
Also, advocacy for protecting novel forms of consciousness is difficult, but Cortical Labs' use of human brain matter for "Wetware-as-a-Service" provides a visceral, concrete example that makes abstract consciousness protection arguments tangible to both policymakers and the public.
Acting now, taking preemptive action against brain farming before the industry has emerged, while both AI and biocomputing technologies remain relatively primitive, offers our best opportunity to establish protective precedents before economic momentum and entrenched interests make restrictions far more difficult to implement.
(This post is being published under a pseudonym while these initial ideas develop. If you're interested in collaborating on policy responses to brain farming, please reach out).
It strikes me as very unlikely that a rudimentary Pong-playing AI running on biological wetware is more sentient than a modern LLM running on digital hardware.
I'd argue that the overwhelming majority of the voting populace would find it easier to visualize future, more advanced biological wetware as potentially sentient. And regulations for one domain, if framed correctly, will influence the other. It seems to me that political willpower will be much easier to build if we start where public intuition is strongest and expand from there.
It strikes me vastly more likely that the biologal wetware used to run a Pong-playing AI is sentient than that modern digital hardware used to run LLM inference is. That is, that running the Pong-playing AI on brain organelles causes/involves instantiation of phenomenally bound valenced moments of experience, which need not necessarily contain any sort of representational content or self-models related to Pong or the "Pong-playing AI", or indeed in this case even be essentially used in the system seen as a "Pong-AI computer". One's likelihood estimates here (and what one thinks might be conscious!) are very sensitive to the sort of theories or models of consciousness considered plausible. Ideally we'd be able to do some sort of robust minmaxing over uncertainty/disagreement, applying the precautionary principle, and recalling that humanity has a pretty dismal track record, until hopefully we understand the situation better.