Monday, December 07, 2009

The FTC

The Federal Trade Commission has released its annual report on "Marketing Violent Entertainment To Children". It's useful, as always.

First, here's how this survey works (quoting from the report, p. 23):
The Commission conducted its sixth undercover shop in the Spring of 2009. In these shops, a contractor employed children ages 13 to 16 as shoppers, who, unaccompanied by a parent, attempted to purchase movie tickets, DVDs, music recordings, and video games at theaters and stores across the country.

That's very straightforward and very easy to understand, which I particularly like.

It's important to notice the age range. If you see some hysterical parasite in the Jack Thompson babbling about "children" in this report, remember that we're talking about, at a minimum, a teenager (probably a seventh grader).

Okay, so how did the video game industry do this year? Here's an excerpt:
As documented in past reports, the video game industry continues to do an excellent job of clearly and prominently disclosing rating information in television, print, and Internet advertising and on product packaging, although the industry still does not require that television ads disclose content descriptors nor that content descriptors appear on the front of the package. Further, the ESRB has been regularly enforcing its advertising code, particularly for the few instances of inappropriate target marketing. The Commission found no evidence of M-rated game ads on television programs with a substantial youth audience that aired prior to 10:00 p.m. and a decrease in the number of M-rated game ads on websites highly popular with teens or children. Nevertheless, a handful of M-rated games were advertised on television shows and Internet sites highly popular with teens. Overall, the Commission uncovered little evidence of inappropriate target marketing through the traditional media.

Major game retailers continue to prevent most children from being able to purchase M-rated games without parental permission. Still, the ESRB should monitor other avenues through which children may be able to obtain M-rated games without their parents’ knowledge or consent, including through the use of retailer gift cards.

The ESRB followed the Commission’s recommendation to conduct research into why, according to the Commission’s 2006 study on video games, some parents felt the system could do a better job of informing them about the level of violence, sex, or profanity in some games. Based at least in part on such research, the ESRB now offers online ratings summaries that provide a more detailed explanation of the content that factored into a game’s rating. This new online tool should prove useful to parents.

Finally, the Commission will monitor developments in the rating mechanisms employed for mobile games. In the meantime, carriers and publishers should continue to provide content information about mobile games and parental controls. Parents can use this rating information to assess the content of games that their children want to play.


That's an almost universal endorsement of the work done by the ESRB, but if you're wondering if this report was a glowing love-fest for everyone, it wasn't, and here's why: no one else is doing as good of a job.

Here's the easiest way to see the enforcement gap. Look at the ability of 13-16 year old consumers to purchase "inappropriate" content by content type:
M-rated Video Games: 20%
R-rated Movie Tickets: 28%
R-rated Movie DVDs: 54%
Unrated Movie DVDs: 58%
Explicit Content Music CDs: 72%

Ouch. If you'll remember, though, in 2000, 85% of test shoppers were successful in purchasing an M-rated video game. So 20% is just an impressive number in absolute terms, it's also a staggering improvement.

As a sidenote, of all the retailers, Toys R Us is Suck City R Us when it comes to enforcement, as 44% of underage consumers were able to purchase an M-rated game. Gamestop/EB, on the other hand, was at 9%, and Target was at 11%.

If you're thinking "Isn't much of this content sold at the same retailers?", you're correct, and the disparity is noted in the report:
Video game retailers generally are doing a good job restricting children’s access to M-rated games, denying sales to 80% of underage shoppers. In contrast, many of these same retailers – particularly Target and Best Buy – are doing a poor job restricting children’s access to R-rated and unrated DVDs and PAL music.

Remember that I mentioned Target? Only 11% of the test shoppers could purchase an M-rated game, but 82% could purchase an explicit content Music CD, 80% could purchase an unrated DVD, and 65% could purchase an R-rated DVD.

In other words, the ESRB is clearly doing something that everyone else isn't.

Sum all that up, and you've got the first paragraph of the conclusion:
The Commission finds that the video game industry has made great strides in restricting the marketing of violent M-rated games to children. Although there remains room for improvement – particularly in the area of Internet advertising – the video game industry outpaces the movie and music industries in the three key areas that the Commission has been studying for the past decade: (1) restricting target-marketing of mature-rated products to children; (2) clearly and prominently disclosing rating information; and (3) restricting children’s access to mature-rated products at retail.

In short: well done.

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