I personally believe you are correct that the numbers are too high to be a placebo. that zappers work, I have no doubt. seems quite obvious in fact. to many of us.
but the FDA is a stupid beaurocracy. whether the numbers add up or not isn't the relevent point to them. it's whether you fulfill enough stupid licensing requirements to say whatever kinds of things you have said. to them, saying "the numbers are too high for a placebo" is too authoritative to say without a license and a controlled study.
you should be legally allowed to say (without a license) what the numbers are, how you got them, what someone else reports as a typical placebo, and what you personally feel the numbers mean. but beyond that (i.e. drawing actual conclusions) it's going to be classified by them as scientific medical research subject to licensing restrictions.