June 7, 2019
Ms. April Tabor
Acting Secretary
Federal Trade Commission
Office of the Secretary, Room H-113 (Annex E) 600 Pennsylvania Ave., NW
Washington, DC 20001
Re: Inside the Game: Unlocking the Consumer Issues Surrounding Loot Boxes Workshop
Dear Acting Secretary Tabor:
The Entertainment Software Association (“ESA”) submits these comments in connection with the Federal Trade Commission’s upcoming workshop, “Inside the Game.” ESA represents the major game console manufacturers and almost all of the major video game publishers in the United States.1 In these comments, we provide an overview of the in-game transaction landscape, including certain transactions involving surprise mechanics, referred to in games by a variety of names, including “loot boxes.” We also outline the proactive steps the industry has taken to inform consumers and, as applicable, parents of those playing games, about gameplay features. We further explain the steps the industry has taken to present them with the choices to tailor their gameplay experience and to empower them with appropriate tools.
