FTC workshop looks into loot boxes

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Gamers call them loot boxes – in-game rewards players can buy that contain a random assortment of virtual items. The loot may help players advance in an online game or allow them to customize their avatars. The rewards may be virtual, but they’ve become a very real revenue stream for game developers. Do loot boxes raise consumer protection concerns, especially for younger players? That’s the topic of an upcoming FTC workshop, Inside the Game: Unlocking the Consumer Issues Surrounding Loot Boxes.

Inside the Game will bring industry representatives, consumer advocates, academics, and others together to talk about the marketing of loot boxes and other in-game purchases, including a discussion of the potential behavioral impact on young consumers. Panelists will explore the in-game transaction landscape, the role of loot boxes in the digital marketplace, and the latest research on child and adolescent behavior in the context of video games and digital transactions. Also, how knowledgeable are consumers about the mechanics and marketing of in-game transactions?

The event is set for Wednesday, August 7, 2019, at the FTC’s Constitution Center conference facility, 400 7th Street, S.W., in Washington, DC. We look forward to seeing you there or you can watch the live webcast.

Two things we’re asking of you in the meantime:

  • Send us your feedback on possible agenda items and potential panelists. Email lootboxworkshop@ftc.gov by June 7, 2019.
  • You can file an online comment about the issues discussed at the workshop. We’ll keep the public record open until October 11, 2019.
     

Comments

I have purchased "loot Boxes" or "keys" to open the aforementioned loot boxes. I feel like it is a gamble, because often times the item you receive can command a market price. It is no different than buying a State lottery scratch-off ticket, sometimes you win and most of the time you lose. I strongly believe that this type of practice if allowed to continue must be watched over like a lottery and bar minors under the age of 18 from purchasing them. I also believe that it might make minors more prone to a gambling addiction and affect them in their adult years. If loot boxes are to continue, then it needs to be you get what you pay for. So in example, if a snake skin gun skin is $4.00, someone pays $4.00 and gets that item. Not buy 20 loot boxes or keys at $2.50 and maybe you get something you want. Thank you for your time.

How do you bar minors from purchasing loot boxes though? It's just like with ESRB ratings, yet parents let their kids play M rated games all the time. I agree that it's gambling and that kids shouldn't be doing it, but another strictly "on paper" regulation isn't going to do much. The government should start investigating these big triple A game companies and take it from there, rather than writing another vague law with a billion easily accessible loopholes.

Your analysis is correct expected for the snake gun part, because that is not a loot box but a micro transaction and those two payment models should be seen as different

When I was in junior high school my friends got me into a game called brave frontier, it's a typical gacha (Games with random drop loot boxes) games, where you can get better character through "summoning". This summoning system requires a diamond which is a premium currency that can be acquired through certain rare mission or buying with your real money. The problem here is that when summoning a monster the system is chance to get random monster, if you didn't get the monster that you want, you feel wanting to summon more to get better monster, which for clueless kid that had access to some money like their savings, or parents money, they'll spend it. Do that for years and the kids unknowingly gets addicted to gambling for random chance of summoning a "Super duper ultra rare mosnter" and that addicting feeling I can still get it even today when I retired from playing those games with gambling, random chance of drop in loot boxes or summoning system. For PC games like Counter Strike with random chance to get better "Skins" is also gambling, even worse with EA FIFA games that makes its player spend hundres of dollars for packs with random player, addicted to get better player for their soccer team, I've seen my friends gets addicted buying packs of EA FIFA games. After you bought those player with your money you felt that you must play those games since you bought something for a large amount of money for that game, making you wanting to spend more money to get better team, making you wanting not to stop playing the game, and the circle continues. It is addicting, and it must stop. It's a bad practice that destroy kids moral, and bad consumer practice

I believe lootboxes are gambling and a serious issue among youth that needs to be addressed. Personally I have a friend who is underage and has spent over 3k dollars on Clash Royale and Call of Duty lootboxes. When I'd asked him why doesnt he just stop he said that he wants to, but cant because he keeps wanting that one reward. If thats not gambling I don't know what is. Lootboxes in video games should be banned!

The loot box system is something that corporations deemed as something good and considered as a non-gambling form of acquiring item (mostly cosmetics) but as they progress people who can see the difference between having a game as normal as possible won't simply cut it, and corporations will make money out of every single thing that a consumer might want, since minors tend to want to have cool stuff like for example an iPhone XS Max or a PS4 Pro, or many a high-end gaming desktop. they will want it even more. This is the same with loot boxes since they give a sense of achievement that "hey, i got a good item from this" will urge people to do it as well, but hey it's just a few dollars worth and you can get something good. if you put it in the gambling sort of way it actually matches what gambling is.

Gambling is sometimes a form of using little money as possible in order to gain something bigger.
as a perspective into loot boxes using small amounts of money to get a good item is also a form of gambling.

Gambling can also be addictive as well as the games you play overtime.
but with games that doesn't have a form of any gambling will make a game bland, but it's up for the developers to make a good game, and for the truth the corporations to make money out of said game.

with that in mind I don't think corporations are allowed to make loot boxes a subtle way of gambling for minors.
hence cancelling this system entirely.

thank you.

In Some games, When you open these loot boxes, you end getting duplicates of the same thing you got already got. To force you to spend more money on loot boxes , just so you can try your luck again. Lootboxes encorages underaged gambleling. Discourages you actually playing the game and getting your monies worth.

Protect the children. Ban the loot boxes.

I've stop purchasing games with microtransactions and loot boxes for myself and family members because it becomes necessary to make purchases to progress in the games. Items are locked behind paywalls and you'd have to work 2-3 times(or more) longer just to obtain them without paying for them. The children in the family have spent too much money for nonsense that was part of the games in the past. They definitely have a sense of how gambling works.

Wouldnt be easier to make all items in a box have the same percentage of obtaining? No more "very common", "super rare" qualities. Kids will still take their parents' credit cards to buy virtual items no matter what absurd new rules you come up with.

I admit i remember buying loot boxes in games, The issue i have with them that it does feel like gambling.Here is the thing, you buy the loot boxes because you want to get a specific thing from it, so you spend 100$ on loot boxes, you open all of them but you don't get that item so what do you do? You spend another 100$ and then another and it goes on and on and on until you have no money left or until you get the item. It's like in Casinos. It's like saying i can stop anytime but then you see that you spend like 2.000$ on loot boxes ... for a game that is 60$ ... so you paid for a 2.060$ game. That is full price, that should have content unlocked by progressing not by spending more money on full price games, What about free-to-play games? Even when the game is free people will support it if you have something interesting to buy, like skins, sure you are paying for them, but you don't have to roll a like 0.01% to just get it. But having loot boxes in free to play games also gambling, they milk you from your money because they know people want what is inside it. They know that kids like playing with beautiful skins. I hope this comment helps understand that Loot boxes should be if not banned, at least restricted and not hinder the progress of how you play games.

PROTECT THE CHILDREN

I bought loot boxes and scratch tickets the mental effect these two have is similar because of the random chance of getting the "jackpot" item. In scratch tickets it is the monetary reward. In video game it is the legendary rare loot that looks better than the lower rarity loot.
Loot boxes and monetary systems in games are designed to make the slow grind (grind meaning long periods of effort, a slow grind is longer periods of effort.) go faster with a small purchase. This small purchase loot boxes or other monetary systems are designed as a slippery slope the more you spend the faster and easier the grind gets. Like the loot boxes and scratch tickets if your purchase is rewarding then you could potentially spend more from the thrill of a good or great reward.
Thank you for reading this far I hope this helps.

Loot boxes in video games a very terrible form of gambling, exploiting children to buying them and earning almost nothing with all the money they spend. This form of gambling is a serious issue and I believe it should be dealt with immediately. No video game should be allowed to have these terrible business practices to try and take more money out of us for wanting something that looks cool or is an item that is better than every other item in a game.

I have played many different games with "loot boxs" or any microtransactions. I can tell you for a fact that you never feel satisfied with what you have received in return. I have spent hundreds of dollars on certain games and then never played them a week later. Its really hard at the moment of offer to determine if this really is a good investment. I think microtransactions as a whole should be outlawed and not even an option.

I've been playing video games my entire life. Loot boxes should be banned completely. They are addictive and it is 100% gambling. Remove this disease from our society. Protect our children.

I generally don't like government intervention into anything, especially the free market. However, I think this is an exception to that rule.
Corporations have been getting away with exploiting their customers for way too long.
This is gambling, plain and simple.

Loot boxes are clearly gambling. Prior to the adaptation of loot boxes into video games, these items were obtained through an in-game reward system. Whether it is a difficult task, collecting in-game currency or a specific drop rate.

Since loot boxes have been added, the in-game rewards have been lessening in favor of offering items through random chance loot boxes. Some games allow loot boxes to be purchasable through in-game rewards but are also offered with real life money. The persons in charge of game creation and game development have the ability to set their own standards of drop chance of the loot boxes as well as chance of in game occurrence of an item.. One can argue that the same item from a loot box is obtainable through normal game play but the enticement to pay for a loot box in hopes to get what you want is clearly gambling. And game publishers know this.

There are a plethora of examples of how this negatively effects the industry as a whole, I hope the FTC will take the time to review each comment and statement. But the core value of a loot box is to purchase it and hope to get what you want and if you don't, buy more. Bad for kids, bad for adults.

Is loot boxes gambling? Yes. Next question.

Loot boxes are without a doubt gambling and have no buisness being accessable in games. Children have easy access to these loot boxes and are introduced to gambling at an unimaginably early age. Indoctrinating them to be addicted to this harmful habit at an early age. We have got to take this harmful construct out of gaming, and protect our children and gamers everywhere. Do not let the big corporations tell you its not addictive and its not gambling because it absolutely is. I was addicted to buying loot boxes when i was 17 on a game called Counter Strike Global Offensive. I was lured by the fact thatbi could spend 2 dollars and fifty cents and could potentially get items worth thousands of real dollars. I ended up spending hundreds on this before i woke up. Loot boxes are toxic monetization and have no place in our country or being accessed by our children.

Please regulate these disgustingly addictive gambling inducing loot boxes , we shouldn't have to pay for random odds to use items that are already in the game, and children shouldn't be aloud to be exposed to this, it will corrupt there souls

As a person, who enjoys games and have been playing them for years, this is my view on loot boxes. They are a system that unfortunately plagues the gaming community. This system stems from the unfortunate gaming market on mobile platforms such as phones and tablets. This system basically works off of the fact that if people want something and you provide them with a "chance" to receive such a thing through online purchases. They will be willing to pay money for it, These individuals willing to pay for lootboxes are more willing to purchase if the object in question is exclusive. Exclusivity, isn't the problem in this case but it is a primary factor for why people spend money and basically accentuates the fact that these lootboxes are bad for the gaming community as well as normal gamers.

Regarding the gaming community, these practices basically encourage companies to make games focused on this type of game, to make games focused on making you pay to play or progress (at a reasonable pace). This clearly harms the gaming community because using the example of the mobile gaming market, almost all of the games that you will find on the mobile market have these systems within them. A common feature found amongst these types of games are what people within the community know as a paywall. Paywalls are systems put in place to halt or severely hinder player progression/enjoyment until said player makes a purchase with real world money. This issue should be stopped in gaming because it basically works to the detriment of players everywhere. For instance, FIFA, Madden, and NBA games games have implemented lootboxes in games for a long time, and due to these loot boxes these games have become stagnant, with minimal graphical improvements, (if any at all) in my opinion a new game should be a game with new features not a changed roster. This is due to the fact that if the "new" game only does what a mod to the old game can do, it isn't a new game, its an expansion that is being sold separately without connection to the old game.

Regarding how loot boxes affect normal gamers, lootboxes have been proven to cause issues similar to gambling. To be more specific, with how lootboxes are made and presented it makes the gamer feel that, one more time feeling, that feeds into more purchases. This preys upon gamers who are not used to how these predatory practices to obtain your money. Considering that these lootboxes are known as gambling in countries like Belgium, these systems should be regulated, if not stopped altogether. Outside of the issue of this being considered gambling, the case can be made that this is negatively affecting children, by introducing them and encouraging them to gamble.

In closing, please ban if not heavily regulate lootboxes in gaming, and ONLY lootboxes. The issue the people face with lootboxes is that it is a chance based system that requires payment. Micro transactions, are not the issue, only lootboxes. and as such there should be no argument against microtransactions as a whole nor should it ever be expanded as such. It should only be lootboxes at this point in time because that is the issue in question.

I was addicted to lootboxes. Im adult now. Rehab in 2016 spoor6 progamme zuid-afrika. This has to stop little childrens have Access to this all app store have it EA Activision . Stop this!! Protect the childrenen

Every time i open a lootbox i feel like an idiot. I got bad loot every time, but when i got something remotely good is an intense adrenaline rush. No diferent from gambling.

i rather not use my full name because this issue is quite embarrassing for me but lootboxes ruined my life, suffering from anxiety and depression those were the only things that made you feel anything and i ended up having 200euro phone bill every month just by buying keys with pay by phone option, when operator shut off my number i took loans in little amounts that ended up in 5000e in a long period of time just to keep up with the new 'limited edition, once its gone its gone' offers. Only thing that stopped me was getting so poor i simply cant afford lootboxes anymore so now my life has turned into constant struggle and stress over money.

I have purchased "loot Boxes" or "keys" to open the aforementioned loot boxes. I feel like it is a gamble, because often times the item you receive can command a market price. It is no different than buying a State lottery scratch-off ticket, sometimes you win and most of the time you lose. I strongly believe that this type of practice if allowed to continue must be watched over like a lottery and bar minors under the age of 18 from purchasing them. I also believe that it might make minors more prone to a gambling addiction and affect them in their adult years. If loot boxes are to continue, then it needs to be you get what you pay for. So in example, if a snake skin gun skin is $4.00, someone pays $4.00 and gets that item. Not buy 20 loot boxes or keys at $2.50 and maybe you get something you want. Thank you for your time.

Lootboxes are a predatory business practice. They are a form of gambling, and should not be accessible to minors.

Loot boxes are gambling, there's no ifs, ands or buts about it. When you crank a slot machine lever you have one of two options: You either get something or you get nothing. When it comes to loot boxes, yes you do technically get something every time, but the perceived quality of the item in question can sometimes be so low that it might as well be nothing, or can be so high that it feels like winning a jackpot.

Companies use the same tactics that drug dealers and casinos use to hook players on spending money for the feeling of opening a loot box. Like heroine, drug dealers will give the "first hit" free to hook customers on the drug. Just like heroine, the feeling of opening a loot box is addicting; like opening a present on Christmas: you could get a Red Ryder BB gun or you could get an ugly Christmas sweater. The perceived quality of the sweater means you got nothing from that present, but if you could buy *more* presents then maybe you'll get that coveted BB gun! You buy another one with excitement and anticipation that tickle the rewards center in your brain enough to be tempted to buy more and more. Some can kick the trend, but others are not so fortunate. Some are so desperate for the Red Ryder that they'll stop at nothing to get it, spending exorbitant amounts of money to "win big" as it were, just like hitting the slots. Some are so desperate for money they'll keep hitting it, and at this point they're so far in deep that gambler's fallacy kicks in and they get trapped in a cycle till either their patience dries up or their wallets.

Companies know all this, and they've been perfecting the ""art"" of the loot box and their psychology on humans to try and squeeze as much money as they can while charging as much as they game for the initial title. Its like a casino you have to pay to get in, and to my knowledge I'm pretty sure casinos don't charge people for just walking in.

The big take away here is that loot boxes are addictive and manipulative, just like hitting the slots at a casino.

Imagine you go to the store. You want to buy milk for your cereal. Now, you dont NEED milk but its very nice to have. You could always drink water and get your dairy needs from elsewhere. However, you really want it anyway. So at the store the drinks section is replaced with a man behind a counter. He offers a chance to get milk. He charges you 2 dollars for each spin. The other options are a Common Orange Juice, an Uncommon Apple Juice, a Rare Lemonade, and the Legendary Reward: Milk.

You say "Alright" and spin for 2 dollars. The man spins his color wheel and it lands on.... Orange Juice. You HATE orange juice. You say to him you dont want Orange Juice and that you'd like your money back. He chimes that there are no refunds and you'll simply have to try again! So you begrudgingly slap down 20 dollars for 10 spins plus a BONUS SPIN ABSOLUTELY FREE.

11 spins later and you have 10 more Orange Juices and a Lemonade. Congratulations. You're down 22 dollars for something that doesnt usually cost more than $1.50 and STILL dont have any milk for your cereal in the morning. You persist, determine to get the breakfast drink you DESPERATELY want. 22 dollars becomes 50, 50 becomes 100, and next thing you know you've spent 500 dollars, you've acquired a lifetimes supply of worthless orange juice, a small bounty of Apple Juices, 4 or 5 lemonades, and FINALLY a gallon of milk. Except.... its skim milk.... not 2% milk like you wanted. Furiously you yell at the counter clerk who shrugs and says "Sorry man, luck of the draw, no refunds!" and waves to you as you slump your shoulders and leave the store way over budget, with tons of useless crap you dont want, and something that cost you way to much and isnt even what you wanted.

This, is what lootboxes are. This story is EXACTLY how lootboxes work for gamers. You're gambling for milk at the store. Imagine the outrage if supermarkets across this great nation did that? Should we allow it in an eco system where young children have access to it?

I'm someone who plays a decent amount of games and can without a doubt in my mind say that loot boxes are a form of a gambling. Gambling can be defined as betting money for a desired material good. Loot boxes do not guarantee anything, just like a slot machine. You play in hopes you win back something equal or greater than the value you put forth but it is never guaranteed. For example EA's NHL 19, during the end of the hockey season they release cards with 99 overalls, best you can get in the game, they then put packs with 'increased rates' of pulling these cards. If I was to buy that pack(loot box), I'm not guaranteed that card. Just a chance at getting it. If I was to put the same amount of money as that pack(loot box) in a slot machine I'm not guaranteed a to get anything back, its a gamble, cause it is gambling. Just like loot boxes are gambling. Only people who think otherwise or the cooperation's who use these practices to target easily manipulated children, grooming them to become life long addicts, or at least as long as they play the game. Gambling is not something children should have access to do, if companies are not willing to find a way to protect children from there greedy practices then they should be forced to remove them from games all together. Thank you if you've taken the time to read this.

I think their a gamble too some times it takes you along time to get something good.

Hey, you! Yes, you! Do you like spending your hard-earned money on slot machines? You do? Then the rest of this post is not for you.

Lootboxes are gambling. There’s no two ways about it unless you’re a two-faced corpo trying to convince us it isn’t. It’s almost reminiscent of tobacco companies trying to convince us that cigarettes didn’t cause cancer how they try to push this anti-consumer business model. Gachas, lootboxes, in-game card packs... Even worse is the fact that these digital goods that have no monetary value can have their drop rates changed on a dime. I’d also like to mention that these gambling mechanics have been linked to gambling addiction problems in various studies.

Thank you for reading through this rant.

Microtransactions/Loot Boxes are a huge problem not only in the gaming industry but also in our economy; it is definitely a huge gambling problem and if this practice continues then it will definitely not only affect the children's adult hood but also be a financial problem in our economy in a few years, the problem has already escalated since it started in 2014 and continues as of today, the microtransaction has not only affects with loot boxes but also other aspects with games, for example Metal Gear Survive a 2018 game release title will charge players $10 for each save slot and it will continue to to go further if this act continues to go on and i will guarentee that it will go out of hand by main publishers such as Activision Blizzard, Electronic Arts, Ubisoft, etc. All i can say is tht these companies cannot be trusted when it comes to public perception or concerns. Thank you for reading this and i hope it will help the future of not only gaming but the future of the kids and out econemy...

Loot boxes is gambling. I play a lot of games, but the games that are using loot boxes are always hiding the % ratio of wining because they know that we need to spend 100$ baying 2$ loot boxes to see if i wing the skin that i want to have and the majority of the time i get noting. Some of then include powerful weapons and abilities into the loot boxes this make the games impossibly to wing if you don't spend 100$ to get a weapon and think about childrens that don't know the value of money yet, and may fall into spending money just to wing a game because the other children are all ready spending money to get weapons more powerful.

Loot boxes are digital slot machines that anyone of age can purchase for digital goods. The methods used to influence consumers to purchase loot boxes directly target children and gambling addicts through predatory practices that involve circumventing the legal system by selling currency: i.e. gems, crystals, coins, etc.

Rampant abuse of these sinister methods of marketing are not only unchecked, but are against the law. Gambling is restricted to a minimum age of 18 yet, these tax evading corporations who harm not only their consumers, but their employees as well, will tell you that purchasing loot boxes is a choice when it is no such thing. In game content is locked off to these slot machines forcing you to buy bucket loads of loot boxes just to pray that you acquire that one unique cosmetic that you cannot unlock directly through any other means, and not the same duplicate item that you constantly get from a rigged system of cruel design.

Digital goods are in fact goods and should be treated as so by the law. Loot boxes are legal gambling for minors and it MUST be investigated. As we have seen with Electronic Arts; companies are more than willing to monetize every single aspect of your purchase to the point that the product is an unfinished mess of code just to sell more content that they cut out of the game directly to harvest more money. Activision trademarking a specific mechanic of matching players who do not have the unique items DIRECTLY WITH players who do have the awesome looking item so they feel like they need to buy loot boxes is a most clear example of what exactly these corporations want from their player base.

The video game industry is broken, toxic, and DANGEROUS to workers and consumers, no other industry is encouraged to actively undermine consumers, or force workers to insane crunch periods that physically, mentally, and emotionally damage themselves just to keep their lights on. No other industry has corporations actively REMOVING content from a product and still consider it finished and legal to sell. No other industry gets away with the sheer amount of illegal sick that the video game industry produces and I'm exhausted from the absolute aggression that games like Overwatch, Call of Duty, Counter-strike GO, Star Wars Battlefront 2 (2017) and others force upon me just to "unlock" content when they're really gate keeping the full experience behind a paywall, even when you pay the asking price, you're just paying more money to be hammered into paying more and more amounts of money for a product that they have no right to call finished.

I've had enough with being treated like cattle by big wig multi millionaire CEO charlatans who think it's okay to scam people time and time again with no consequences. I'm tired of these big budget corporations who nickel and dime the very people who built them up only to claim that their titles fell "below expectations" when they sell millions of copies because they have an absurd idea that their games will sell beyond a reasonable threshold.

I hope things get fixed down the road, because video games are truly pieces of art. Whether visually stunning, awe inspiring scenery, or exhilarating fast paced racing, or thought invoking strategy, we all have something to gain from video games which is enjoyment and fun.

Loot boxes are not fun.

The lootboxes teaching gambling to kids, getting them used to gambling at a younge age. Companies that are using lootboxes are gaining money off of victims who can't help themselves because they are addited to gambling.

As an avid game enthusiast, Loot boxes are destructive. They are a monetized, lopsided gambling alternative that targets and harms children, and destroys the consumer experience. It is harmful to this nation and the industry as a whole.

What they said ^^^

Loot boxes is just like gambling because with a slot machine you never know what your going to get and it's the same for loot boxes. Loot boxes can become addictive, so companies like EA and Activision have been thriving for years from it, which shows from the focus of loot boxes in their work. Madden and FIFA have been EA most profitable games because of their MUT modes use addictive loot boxes that they call Packs. Weather loot boxes are getting used for weapons, characters, cosmetic or other items, and they are just as addictive as people who continues to go to the Casinos. Loot Boxes have become such a issue that several European countries have banned them because how addictive they are to young people, but it's not in just these games. Loot boxes have also been the reason for the increase of the mobile game growth in the profit and in the gaming community. Even small children become addicted to these colorful games that use loot boxes that are just one click away from them.

As many have already stated, the current design of loot boxes have all the hallmarks of gambling, be it lottery tickets, slot machines, etc. The same thrills, risks, and potential for addictive behavior. There is no need for me to reiterate that here.

What I will go over is what can be done to solve the issue and deconstruct a likely comparison made in argument for the current loot box system. First, the comparison. Some will equate loot boxes to the randomness currently existing in products not seen as gambling such as packs of baseball cards, another product that is aimed at a market that includes children. At first glance, this seems like an apt comparison, but it is not. Baseball cards have a strong secondary market allowing the consumer to find only the ones they are looking for and pay what is deemed market price for those specific items. Also, the consumer has a secondary market in which they can sell or trade their unwanted cards at what is deemed market price for those items. The vast majority of current game Loot boxes do not allow for a secondary market of their items, and virtually none of them allow for real money sales of their digital items. Their is currently no way in the vast majority of these games for the consumer to get any of the money they spend on loot boxes back from the selling of the items they do not want or no longer need. Not that I am advocating for that as a solution here, just making that point as a large distinction between the current loot box economy and a likely comparison to baseball cards and the like is the absence of a secondary market giving tangible value to the items purchased even if they are not the desired items of the transaction.

Now, I am not here to eliminate the free market. If a person is of age and of sound mind, then they should be able to spend $2,000 on a digital item if they so desire. I am here to suggest a solution that works for both the game companies and the consumers. The creation of a secondary market for all of these digital items creates more issues than it solves, and that should not be the path forward. From a consumer protection standpoint, we should want to make all the risks clear and visible from the start as well as making the undesired items purchased from loot boxes not worthless without creating a real money secondary market.

To that end, here is my set of recommendations that I truly believe is a very sensible middle ground. Every Loot Box should have the odds of receiving an item of certain rarities very clearly marked before and after purchase. For example, this Loot Box has a 1:4 chance of getting a rare item, a 1:9 chance of getting an elite item, and a 1:100 chance of getting a legendary item. Furthermore, no item within a specific rarity should be any less likely to be obtained than any other item of that rarity (no making rarities within rarities). For example using the previous example, a specific legendary item should not be any harder to get from a Loot Box than any other legendary item, the odds should be the same. Next up is providing use for unwanted items. Every game that has Loot Boxes will be required to allow the exchange of any item found in the Loot Boxes by trading in no more than 5 items of the same rarity of the desired item received from those Loot Boxes. For example, a game has Loot Boxes and the elite rarity is a 1:9 drop from the Loot Box, Player A has accumulated 5 elite rarity items from Loot Boxes, Player A must be able to trade those 5 elite rarity items from Loot Boxes to receive any 1 specific elite rarity item possible from that Loot Box that they want in exchange. The game will have the option of lowering that number if so desired, but they cannot require more than 5 items of that rarity to be traded in exchange for another specific item of that rarity. Lastly, to ensure there is a way around the gambling aspect of Loot Boxes every item available in a Loot Box that is purchased with cash must also be purchasable by cash and also display the estimated cost to acquire the item by buying Loot Boxes and trading in game at the in game ratio (no higher than 5 to 1) for that specific item. For example, using the 1:100 chance of getting a legendary item and there are over 10 different legendary items in the Loot Box and the game has chosen to stick to the 5 items required to trade in and not lowered that and that the Loot Boxes cost $1 each, the Estimated Price to Acquire a specific legendary item would be $500 (1:100 so on average 100 $1 Loot Boxes needed to get 1 legendary item, then you would need 5 legendary items to trade in for this specific one.) and that $500 Estimate to Acquire via Loot Boxes would be required to be shown on the item page to purchase the item. The price the game decides to charge in cash for the item without purchasing the Loot Boxes will also be displayed on this page and that price is to be determined by the game company. (In my original idea I had forced a discount over the estimated price for purchasing the item outright with cash, but that should not be forced onto the game company. It should be the game company's decision to offer a discount or even charge a convenience fee over the estimated Loot Box price.) Also, game companies will not be required to exchange any number of lesser rarity items to equal a higher rarity item. They may do so if desired, but that will not be required. For example, even though the pack says 1:100 legendary it does not mean the game has to let you trade 100 common items for a legendary.

This set of recommendations does not completely remove the gambling-like nature of Loot Boxes, but it does bring them closer to something already on the market in baseball cards. It reduces risks for consumers and puts both a clear price of plainly purchasing the item and the estimated price it would cost if you tried your luck with the Loot Boxes in front of the consumer from the get go explaining the risks to the consumer then. It also provides the consumers with something akin to a secondary market in requiring that their unwanted items have some value in regard to what they do want without it being so minuscule as to be nearly worthless. From the game company standpoint, this is a much better solution than creating a real money secondary market and all the issues that will cause. This also allows game companies to continue with this practice in a way that is not as harmful to the consumer. It would still need to be regulated to avoid minors from being able to engage in the Loot Boxes with real money, but allowing them to purchase the item for cash if allowed by state and federal laws and agreed upon from their parents or guardians per the game's EULA.

Thank you for your time.

I could debate this all day, and explain in great detail everything related to the issue, let's hope the people who discuss this actually have SOME clue as to what it is they're talking about. Gaming and the internet is still a foreign and totally misunderstood concept by the older generation. No idea how this will play out.

Loot boxes are predatory for children. How many times do parents say oh its ok a dollar or 5 for a virtual item and leave their card in the game pay or card system saved to see kids buy over $100 worth of in game items because it took about an average of 20 loot boxes to get an item with better power points that the developers and big game companies make up ON PURPOSE to make money. Well what about not pay to win loot boxes? Loot at valve steam market . DO you know how many look boxes and take to get this super rare non pay to win item that sells for $100 or up on the steam market ? an average of at least 50 loot boxes each at $2.50 and all this kids want that item to sell or show off , companies like this make loot boxes and pay to win subscriptions to profit just so kids can have the satisfaction of winning, they are pretty much selling a virtual high and or stimulate the brain for a chance that might give u satisfaction and excitement , the rush for the win and to continue to keep paying and playing for that BIG SCORE!...but wait i just realized something.....i just described a slot machine at my local Indian reservation.

100% SUPPORT THE BAN AND PAY TO WIN MECHANICS!

My first experience with loot boxes was in Bioware's Mass Effect 3. Several members of my family including my own mother work or have worked in a casino. My aunt and uncle are very much into gambling so much so that it is their main pastime. They even travel to Las Vegas every winter for 2 months now that they are retired. My point is I know gambling, I've seen it, my family has extensive conversations about it. As for myself I seem to not get addicted to gambling. The anger of being robbed hits me before the excitement of winning or possibly winning. So, when I encountered loot boxes I immediately felt it, I knew it was gambling. The math is clear, as a society we talk about the odds of winning all the time. In my family we calculate the chance of making profit all the time. Nobody makes money gambling. It is simply not a viable source of income. The loot box phenomenon in the gaming industry is serious. Players use real money and they have similar odds of winning as gambling. Yet, these players are children. Gambling is illegal for children because they don't understand. Why do we allow games that are very clearly meant for children to include the very adult game of gambling? What does it say about our country that we would allow the most innocent among us to be preyed upon by something that will absolutely damage their lives and future? What children gain from loot boxes under even the best outcomes does not improve their lives. In that way it's even worse than adult gambling. Not only do they loose real money but when the game console is shut off or the electricity is off they have absolutely nothing to show for it.

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