Psychology and loot boxes
3.1
Despite the view that many of the legal definitions of gambling do not
extend to loot boxes (both in Australia and internationally), submitters argued
that some types of loot box are so functionally similar to, or share enough
characteristics with, other forms of gambling that they should be regulated
accordingly.
3.2
Evidence was twofold: that some types of loot boxes meet the
psychological definition of gambling; and that loot boxes use psychological
mechanisms in the same way that other forms of gambling do, in order to encourage
play.
3.3
Submitters also argued that loot boxes may cause gambling-related harms,
encourage gambling activity, and familiarise children and young people with
gambling and gambling-like activities.
Psychological definitions of gambling
3.4
It was argued that many loot boxes meet the psychological definition of
gambling, even where they do not meet the legal definitions. In particular,
submitters highlighted the criteria used in psychology literature to
distinguish gambling from other forms of risky behaviour. The criteria used to
identify gambling activity are as follows:
- the exchange of money or valuable goods;
- an unknown future event determines the exchange;
- chance at least partly determines the outcome;
- non-participation can avoid incurring losses; and
- winners gain at the sole expense of losers.[1]
3.5
Dr James Sauer and Dr Andrew Drummond (Sauer and Drummond)
explained that to meet these criteria, a loot box system would need to:
- be purchasable for real-world currency;
- be accessed after payment is made;
- provide a reward determined at least partly by chance; and
-
be optional (i.e. players must be able to choose not to buy the
loot box).[2]
3.6
Sauer and Drummond submitted that the fifth psychological criterion,
that players profit at the expense of losers, would only be met if the obtained
reward provides winners with a direct competitive advantage over losers in
future gameplay. Sauer and Drummond described this as 'a conservative
approach'.[3] Dr Sauer told the committee:
We've adopted a fairly conservative interpretation of this
and thought that it only occurs where players might gain some sort of
real-world competitive advantage in future games. This is not the only way you
might conceptualise value. The combination of scarcity of items, desirability
of items and social status of items may well contribute to people wanting those
items, and the desirability and value that they have to people.[4]
3.7
As noted in Chapter 2, Sauer and Drummond examined the loot box
mechanisms contained in 22 games released in 2016 and 2017. Sauer and Drummond
examined such mechanisms against the above established psychological criteria
for gambling and found that:
Nearly half of the games reviewed met all the psychological
criteria, and more than one-in five met the cash-out criterion (allowing
players to cash out winnings). These cases appear most clearly to constitute a
form of gambling.[5]
3.8
It was however noted that the study only examined major home game-console
and PC releases and did not analyse smartphones and tablet releases of video
games. Dr Drummond told the committee that 'market research does suggest that
loot boxes and micro-transactions for chance-based items are much more common' in
mobile games. As such, the overall percentage of video games meeting the
psychological criteria for gambling could not be assessed; however, it is
possible that the overall percentage of loot boxes meeting the criteria 'is
likely to be a little bit higher' with the inclusion of mobile games.[6]
Psychological mechanisms
3.9
Submitters also presented evidence that loot boxes share psychological
mechanisms with other forms of gambling. These include:
- variable ratio reinforcement schedules;
- game-play experience such as sensory feedback;
- entrapment and other mechanisms encouraging continued spending;
and
- ready and constant availability.
3.10
The following sections will outline the evidence received in relation to
a range of mechanisms commonly found other forms of gambling. The following
sections will also explore the way in which these mechanisms influence and
affect players; and the potential for gambling-related harms to be experienced
by players as a result of these mechanisms.
Variable ratio reinforcement
schedule
3.11
Operant conditioning, or the rewarding of certain behaviours to
encourage the repetition of such behaviour, is a well-recognised concept.
However, one of the key findings in psychological research into operant
conditioning is that 'the most effective way to encourage a behaviour is not to
reward every instance of that behaviour. It's to deliver rewards on a seemingly
random schedule...this is...a variable reinforcement schedule'. Dr Sauer explained:
What this means is that on average a behaviour might be
rewarded once every 10 times it's committed, but in practice it might be two
instances to your first reward, 13 instances to your second reward, five
instances to your third reward and so on. This is called a variable ratio reinforcement
schedule. What it does, in addition to offering rewards at intermittent points
in time or following a certain number of responses, is that each time the
player commits the behaviour but doesn't get the reward they get a little tinge
of disappointment, but they also think, 'Well, I'm one step closer to getting
the reward the next time'.[7]
3.12
Of particular note, variable ratio reinforcement schedules result in
people quickly acquiring behaviours, and repeating these behaviours frequently,
in the hope of obtaining a reward. Such behaviours are 'extremely persistent'
and variable ratio reinforcement schedules are a central feature of poker
machine gambling.[8] Dr Sauer described these behaviours as 'robust against extinction' and noted
that 'it's very difficult for players to stop repeating the behaviour, even
once the rewards become more and more infrequent'.[9]
3.13
The Royal Australian and New Zealand College of Psychiatrists (RANZCP)
submitted that concurrent with such behaviours are the 'adaptation of neural pathways
which further encourage these behaviours'. It also stated that:
While most people who engage in gambling activities with a
variable ratio reinforcement schedule do not develop problem gambling, many do,
and these are likely to be people with pre-existing vulnerabilities.[10]
3.14
It was argued that the variable ratio reinforcement schedule that
underpins many gambling models, similarly underpins the mechanism of loot
boxes. As noted above, variable ratio reinforcement schedules involve a reward
structure where players do not know how many purchases are required to obtain
an item sought[11] and Sauer and Drummond explained that in the context of loot boxes this means
that:
Across multiple purchases, players might receive a high value
item on average every X number of times they open a loot box (where X
represents a number of openings determined by a pre-defined algorithm). For
example, a game with a 10% chance of a high value item in a loot box may result
in success, on average, once for every ten boxes purchased. Critically,
however, the exact number of boxes that must be purchased to obtain a
valuable item varies.[12]
3.15
The RANZCP assessed the risk to players who engage with loot boxes of
developing gambling-related harms as likely being similar to the risk posed by
other forms of gambling that utilise variable ratio reinforcement schedules.[13]
Predatory monetization schemes
3.16
Dr Daniel King and Professor Paul Delfabbro, School of Psychology, The
University of Adelaide, described loot boxes as a predatory monetization scheme
in an editorial for the academic journal Addiction in June 2018. King
and Delfabbro stated that loot boxes contributed to increasing the similarities
between gaming and gambling, and created a potential for financial harm. King and
Delfabbro defined predatory monetization schemes as 'purchasing systems that
disguise or withhold the long term cost of the activity until players are
already financially or psychologically committed'.[14]
3.17
For King and Delfrabbro, loot boxes encouraged repeated player spending through
intrusive and unavoidable solicitations, limited disclosure of the product, and
systems which manipulate reward outcomes to reinforce purchasing behaviours at
the expense of encouraging skilful or strategic play.[15]
3.18
In addition, King and Delfrabbo noted that player data is being
collected and utilised to manipulate the nature and presentation of loot boxes
to maximise the likelihood of players making purchases. In some cases, the
prices and chances of winning virtual items are manipulated according to the
player's spending and playing habits in the game. King and Delfabbro concluded
that such schemes may entice some players to spend more money than they have,
or can afford through the use of credit cards.[16]
3.19
Dr Marcus Carter similarly submitted that 'it is possible that some loot
boxes are configured with variable odds, which change based on factors such as
player profile (e.g. less likely to reward wealthier players) or behaviour
(e.g. more likely to reward players the more they spend)'. Dr Carter described
the latter as an 'example of predatory and manipulative practice' which
exploits the 'Gamblers Fallacy', that is, 'the expectation that the probability
of winning increases with the length of an ongoing run of losses'.[17]
3.20
International researchers, Rune Nielsen and Pawel Grabarcyzk, also noted
several other characteristics which are likely to be manipulated by the
configuration of loot boxes. For example, players of Marvel Strike Force identified
that they had been given different odds in the game's chance-based
micro-transactions. Dr Carter stated that 'this is easily implemented when
reward cannot be traded for real-money, potentially making them more harmful
than rewards that can be subsequently traded for money'. However it was noted
that investigating such practices is 'almost impossible' as such practices are
kept strictly confidential. Dr Carter concluded that the potential impact of
such practices on player's attitudes to real-world gambling are 'also
potentially problematic, and may be contributing to the explosive growth of
problem gambling in 18–25 year old Australian men'.[18]
3.21
The committee also received evidence from individuals concerned that
video game developers and publishers are 'using advanced algorithms to
encourage and then positively re-enforce the purchase of...loot boxes and the
items they contain within'. Ms Stephanie Gray explained that games 'match make'
to ensure that players that do not purchase loot boxes are forced to play
against those who have made purchases. The virtual items won through loot boxes
are significantly more powerful than free items and the player who has not made
purchases is likely to lose repeatedly. If a player then decides to purchase
loot boxes, they are likely to then be matched with those who have not,
allowing them to begin winning games. Ms Gray submitted that this positively reinforces
the decision to purchase a loot box.[19]
3.22
Dr Paul Cairns, Reader in Human-Computer Interaction, University of
York, compared the development of electronic gaming machines (EGMs) with the
development of loot box mechanisms. Dr Cairns noted that the mechanics of EGMs (also
called pokies, poker machines or slot machines) have been researched and
developed to ensure effectiveness, particularly in ensuring that players
continue to spend money. Dr Cairns stated:
...the research in slot machines is very clear. It's highly
effective if you get those ratios right in what's called offering a smooth ride
to extinction; in other words, literally taking all the money off the gambler.
They worked over decades to get these proportions right and to get the balance
right in order to monetise slot machines.[20]
3.23
Dr Cairns went on to note that though game designers and developers are
not working 'at the same industrial level at which slot machine developers are
working', nevertheless 'there are people looking at these analytics, and if
their job is to increase monetisation they will be doing exactly the same thing
in the loot box context'.[21]
3.24
It was also highlighted that players are 'heavily incentivised to permit
mobile games to send them push notifications, for example to remind them when
they can play again'. Dr Carter stated that:
These appear like text messages on a players' phone. Some
games send push-notifications about limited time offers such as a discount on
purchasing in-game currency, or a for free 'loot-box' for logging in every day.
Large companies likely spend considerable resources on identifying the most
effective way to send these messages to encourage player to engage in in-app
purchases, many of which (as discussed) heavily resemble gambling.[22]
3.25
Dr Carter concluded that 'for some players (many of whom are children),
this would be like having a slot machine in your pocket that actively
encourages you to gamble at your most vulnerable moment'.[23]
Optional participation
3.26
However, the Interactive Games and Entertainment Association (IGEA)
argued that 'loot boxes are simply one form of optional micro-transaction that
will always provide players with in-game items. They are not necessary or
required to enjoy, progress in or complete a video-game'.[24]
3.27
Mr Ron Curry, Chief Executive Officer, IGEA told the committee that loot
boxes are not predatory because 'loot boxes are not the only way to do those
things [game achievements], and nor is a loot box the only way to finish a game
for example'.[25]
Game-play experience
3.28
A number of submitters raised concern that the game-play experience of
opening loot boxes is similar to the experience of playing EGMs. For example,
like EGMs, loot boxes:
...often encompass rapid playing speeds combined with rapid (or
in the case of micro-transactions, immediate) payouts, the potential to quickly
and easily multiply bets/transactions, and audio-visual effects to enhance the
gam(b)ling experience.[26]
3.29
In particular, the sensory feedback provided to players during the
opening of a loot box was compared to those provided by poker machines. For
example, Mr Lindsay Shaw, Senior Policy and Knowledge Officer, Victorian
Responsible Gambling Foundation (VRGF) stated that when a 'loot box opens
there's flashing lights and there's music, the same as a poker machine'.[27] The committee also heard that the animations used to deliver loot boxes in
games are similar to those used by EGMs. For example, Mr Glen Bruton
submitted:
I would suggest you watch some of the animations used in
games when 'opening a loot box', try to divorce them from similar animation and
sound techniques used on poker machines, you probably won't be able to.[28]
3.30
Similarly, Mr James Donnelly stated:
When opening the boxes, the possibilities of what may be
ultimately draw for the player is scrolled across before them on their screen.
This is identical to the way a slot machine scrolls around before ultimately
stopping. As with the slot machine, the graphic display eventually stops on an
item, which is given to the player – regardless of whether that is what they
desired or not.[29]
Monitoring of spending
3.31
It was submitted that 'users can quickly become unaware of how much
money they have spent'.[30] The ability for players to monitor and control spending on loot boxes is
affected by a number of factors including: the use of in-game currency and the
dematerialisation of payment; one-click purchasing; and a lack of real-time
feedback.
3.32
These are mechanisms commonly found in other forms of gambling, and
which can contribute to the development of gambling-related harms.
In-game currency
3.33
The committee received evidence that many video games use items such as
crystals, gold coins, hearts or other symbols appropriate for the specific
genre of the game to represent currency for micro-transactions. As such,
players purchase such in-game currency with real-world currency and then
purchase virtual items such as loot boxes with the in-game currency.
3.34
The use of so-called in-game currency can affect players' ability to
track purchases and monitor spending. The Australian Council on Children and
the Media (ACCM) submitted that 'the effect of virtual money use is the
dematerialisation of payment' where 'the user often has no clear idea of [the]
actual cost' of the loot box.[31]
3.35
Similarly, Dr Drummond explained that 'there is some research that
suggests that this conversion into abstract currency may also increase people's
willingness to spend money when it is in abstract forms rather than real-world
dollars'.[32]
3.36
Mr David Wanden, a video game player, told the committee that many games
use digital currencies which are purchased with real-world currency. Mr Wanden
submitted that:
The idea behind this strategy is to detach you from your
money so that you are more comfortable spending it much like casinos use chips
or credits that you gamble with rather than your real money. For example $4.99
might get you 500 'coins' 2 loot boxes cost 480 coins. You spin the slot on 2
loot boxes and then have 20 coins left over that you can't spend so if you want
to use them you are forced to spend more money.[33]
One-click purchasing
3.37
The ease with which micro-transactions can occur was highlighted as affecting
players' ability monitor spending. Dr Drummond explained that particularly with
tablet and phone games, in-app purchases are 'incredibly easy'. Dr Drummond
stated:
Once you have entered your card details, all you have to do
is re-enter your password in order to get those in-app purchases, which may be
for chance based items. So it is very easy for players in those mediums to
spend money. It is a little bit harder for players in more conventional mediums
like consoles and PCs to spend that money; usually they would have to drop out
of the game and go to a separate marketplace. But within smartphone releases
and tablet releases it is much easier.[34]
3.38
Dr Cairns, University of York, told the committee that 'the physical
world puts natural barriers in the way of people's behaviour'. In contrast,
online activities are characterised by 'velocity and volume', that is,
'computers can do...things quickly and in large quantities', including making rapid
and repeated purchases of items such as loot boxes. Dr Cairns explained:
...if I wanted to go and buy a
Kinder egg I have to pop down to the shop and buy a Kinder egg, or I can buy a
box full of Kinder eggs. But once I've spent that and opened them, I'd have to
go back to a shop again, and that slows things down, because it is a physical
action. When I am on a computer, I can keep pressing 'buy' at a rate as fast as
my finger can click. So there is velocity is there. And of course the volume is
that I can spend as much as I think is reasonable as well...If I was an addicted
book reader I could buy a book a minute on Amazon without any problem
whatsoever. Nothing would stop me. And it is the same with loot boxes and
games. There's nothing stopping people spending at that volume and that
velocity. It is a difference in nature, not a difference in quality.[35]
3.39
Dr Drummond concluded that such ease of purchase creates 'the hazard of
not being able to receive real-time feedback about the amount of money that is
being spent'.[36] Similarly, Mr Tony Phillips, VRGF, told the committee that where users are at
risk of losing control of their spending, the tracking of spending is 'really
important'.[37]
Entrapment
3.40
The committee also heard that gaming micro-transactions for chance-based
items can reinforce and perpetuate continued play which sustains ongoing
spending through so-called 'entrapment' (when an individual believes they have
invested too much to quit).[38]
3.41
The RANZCP explained that continued play through entrapment is similar
to individuals 'chasing losses' in traditional gambling and that 'people who
engage in micro-transactions often report their primary motivation as a desire
to extend play, as well as an aim to chase lost credits and to speed up play'.[39]
3.42
The ACCM similarly highlighted the work of King and Delfabbro which stated
that in entrapment situations, 'players will often spend an escalating amount
of money that begets further spending on the game'. King and Delfabbro
explained that in the context of loot boxes:
The investment of an
irretrievable sum of money in pursuit of desirable virtual items may be seen by
players as an investment to the extent that it will increase the likelihood of
obtaining these items. In this connection, spending more and more money on loot
boxes may have a 'sunk cost' effect that serves to justify continued
expenditure.[40]
3.43
Entrapment can also be exacerbated by the use of virtual currencies, and
association or play with other individuals who are similarly trapped. King and
Delfabbro explained that 'entrapment by micro-transactions may occur because the
costs are less salient, because these transactions are represented as virtual
credits or credit card debt'.[41]
3.44
Further, the exposure to other online players who are entrapped may
cause players to make 'maladaptive purchasing decisions'. King and Delfabbro
explained:
Observing other players' spending and opening of loot boxes
with favourable outcomes may provoke counterfactual comparisons (e.g. 'If only
I had spent more ...') that sustain players' spending.[42]
Potential for harm
3.45
Submitters noted that empirical evidence regarding the effect of loot
boxes, and the potential for harm, is scarce due to such mechanisms being a
'relatively new and still evolving product'.[43] For example, Sauer and Drummond submitted that 'the current body of evidence
does not yet allow us to draw confident conclusions about the short- or
long-term consequences of engaging with loot box systems'.[44] Similarly, Dr David Zendle, Lecturer in Computer Science, York St John
University, told the committee that:
...the literature is just...beginning with loot boxes, which is
one of the things that make your decision-making very hard. There is very
little evidence for you to go on. Certainly when it comes to empirical studies
there is very little...It will take months, if not years, for the literature to
gain the nuances that you're talking about and be able to inform you in any
empirical way.[45]
3.46
Dr Carter noted that 'there is little existing research into the impact
of these mechanisms on players (adults or children) and factors such as their
positive or negative experience with monetisation, and how it distorts or
influences their perception of, and attitudes towards real-world gambling'.[46]
3.47
However, the committee did receive evidence regarding 'the only
large-scale study in existence regarding the effects of loot boxes'. This study
was found to 'strongly support claims that loot boxes are psychologically akin
to gambling' and 'suggest that there is a serious risk for loot boxes to cause
gambling-related harm'.[47]
Zendle and Cairns study
3.48
The study conducted by Dr David Zendle and Dr Paul Cairns 'investigated
links between loot box spending and problem gambling'. It surveyed 7422 gamers
and measured how much they spend on loot boxes, and the severity of their
problem gambling.[48] Dr Zendle explained:
...we have run two studies. The first study was run on about 7½
thousand gamers, and the second study was run on about a thousand gamers and
replicated the results. We got the same thing both times, which is always nice
to see in science, because it suggests that the effect you are seeing in the
world is real and it is robust. The first time we measured categories of
spending. We asked people: 'Do you spend less than a dollar? Do you spend
between $1 and $5? Do you spend between $5 and $10?'...In the second study we
asked directly: 'How much are you spending in dollars? Give us the absolute
amount.'[49]
3.49
The study found that the more severe an individual's problem gambling,
the more they spent on loot boxes. In particular, there was 'about a $10 or $15
difference per month in spending on average between problem gamblers and
non-problem gamblers'. Dr Zendle stated that it is important to note that
utilising averages 'discounts the effects of very, very extreme problem
gamblers'. Dr Zendle explained:
We saw five or six people within that sample who were
claiming to spend $2,000 or so a month. In general, we see about one per cent
of the people in each of our studies is spending $300 or so, or upwards, per
month on loot boxes. So you have got this long tail in the data where at the
end you have a group of people who are spending really, really large amounts.[50]
3.50
Zendle and Cairns submitted that the relationship between problem
gambling and spending on loot boxes was found to be 'neither trivial, nor
unimportant' and that the amount that individuals 'spent on loot boxes was a
better predictor of their problem gambling than high-profile factors...such as
depression and drug abuse'.[51] Dr Zendle stated:
We've found that loot boxes
are linked to problem gambling. The worse that people's problem gambling is,
the more they spend on loot boxes. We have demonstrated and replicated this
relationship in studies with over 8½ thousand participants. The link between
problem gambling and loot box spending is neither small nor trivial. Our
research has shown that this relationship is comparable in size to links
between problem gambling and important factors like alcohol dependence, drug
abuse and depression.[52]
3.51
Zendle and Cairns noted that though the study 'provides the sole
empirical evidence of a link between loot box use and gambling related harm', it
is however 'important to clarify that the nature of this harm is partially
unclear due to the correlational nature of the study'.[53] Dr Zendle explained that the relationship between loot boxes and gambling uncovered
by the study indicates one of two things:
Loot boxes may well be acting as a gateway to problem
gambling amongst gamers; hence the more gamers spend on loot boxes, the more
severe their problem gambling becomes. Alternatively, it may be the case that
individuals who are already problem gamblers instead tend to spend more on loot
boxes.[54]
3.52
Dr Zendle highlighted that 'problem gambling is characterised by
excessive, harmful and often uncontrollable spending on gambling activities'. As
such, the characteristics of loot boxes may lead gamers who are also problem
gamblers to spend large amounts of money on loot boxes; just as they would
spend on other forms of gambling.[55]
3.53
Zendle and Cairns hypothesised that loot boxes are either causing
gambling problems, or are providing an opportunity for game developers to
'exploit addictive disorders amongst their customers for profit'.[56] Dr Zendle stated:
Our research suggests that loot boxes either literally cause
problem gambling or, alternatively, allow games companies to exploit serious
gambling problems amongst their customers for massive monetary gain. It is
important to remember that loot boxes are projected to generate as much as
$US30 billion in revenue this year alone.[57]
3.54
It was also submitted that the results of the Zendle and Cairns study supports
the position of academics who argue that loot boxes are psychologically similar
to gambling. Dr Zendle explained:
Spending large amounts of money on loot boxes was associated
with problematic levels of spending on other forms of gambling. This is what
one would expect if loot boxes psychologically constituted a form of gambling.
It is not what one would expect if loot boxes were, instead, psychologically
comparable to baseball cards.[58]
Caution advised regarding Zendle
and Cairns study
3.55
In response to the evidence provided by Drs Zendle and Cairns, the IGEA
provided the committee with a supplementary submission expressing concern with
aspects of the study conducted.
3.56
IGEA expressed concern regarding the methodology utilised in the study
and questioned 'whether an online poll using a self-reported sample of adult
gamers recruited from Reddit...provides a sufficiently robust methodology for a
study that may be used to inform regulatory decisions in Australia'. IGEA also
questioned the reliability of responses, and noted that 'it does not appear
that the research conducted by Drs Zendle and Cairns has had the opportunity to
be peer-reviewed at this time'.[59]
3.57
IGEA stated that it is 'worried that, in the environment of limited academic
research, the Committee will be tempted to place disproportionate reliance on
the research conducted by Drs Zendle and Cairns'.[60]
Analogous evidence
3.58
Submitters, in acknowledging the lack of research into loot boxes
specifically, offered an analysis of the potential risk of harm from loot boxes
by examining their similarities to other forms of gambling which have been more
widely researched. For example, the VRGF compared loot boxes with poker
machines, and wagering to assess the risk of harm generators associated with
each type.[61]
3.59
The VRGF found that loot boxes and poker machines share the following
risk of harm generators:
- reinforcement through random rewards;
- associated with chasing losses;
- system of rewards are complex and hard to understand (though poker
machines have a designated return to player);
- gambler's fallacy;
- accompanying visual and audio stimulation;
- near misses built into presentation of result (shows possible
wins apparently just going past before final result);
- immersion (zoning out and losing track of time and spending);
-
high accessibility and availability; and
- appeal to children (though poker machines are strictly regulated
regarding location).[62]
3.60
Similarly it found that loot boxes and wagering share the following risk
of harm generators:
- push offers during sessions;
- offers that are hard to understand in terms of return for
investment and actual price;
- ability to hide and play in private;
- very high levels of access (weak structural barriers to playing);
-
tokenisation or expenditure utilising an abstract form or an
account;
-
social interaction which may cause a competitive or reinforcement
effect leading to more expenditure or obsession; and
- it can be hard to keep track of expenditure.[63]
3.61
The VRGF also found that poker machines and wagering in fact offer
consumer protections to players which loot boxes do not. These include
self-exclusion, and the ability to track expenditure and play in some
jurisdictions.[64]
3.62
The RANZCP similarly submitted that the ease with which gaming platforms
utilising loot boxes can be accessed 'bears similarities with the rise of
interactive and online forms of gambling'. It particularly noted that online
platforms provide ready and constant availability and stated that:
New gamblers are more easily recruited online, especially
young people who are highly involved in web-based activities and who already
have particular vulnerabilities with regard to problem gambling. In addition,
online gambling sites are accessible 24 hours a day and do not require the
person to leave their home. Mobile and internet games that involve
micro-transactions for chance-based items carry many of these same risks.[65]
Those most likely to be vulnerable
to harm
3.63
Though research into the effects of loot boxes is limited, submitters drew
on the research into other forms of gambling to hypothesise that the following
groups of people are more likely to be vulnerable or susceptible to
gambling-related harms through interaction with loot boxes: children; people
with impulse control issues; and people with mental health issues.[66]
3.64
It was suggested that the potential harm to players from loot boxes can
be divided into three categories:
- unhealthy obsession – where players become focussed on the game
in a way that results in negative outcomes or losses for themselves or those
close to them;
- spending more than they can afford – where players lose control
or judgement to the extent that they suffer financial losses that result in
negative consequences for themselves or those close to them; and
- spending more time than they can afford – as a product of
immersion and obsession, players lose track of time and incur negative
consequences for themselves or those close to them.[67]
3.65
The VRGF noted that children are still developing cognition and impulse
control and are therefore particularly vulnerable to conditioning effects, and
promotions more generally. Children are also highly attracted to games, and in
many cases, children are the desired audience. The VRGF submitted that 'even
without random reinforcements there are many existing immersive features in
games that already cause loss of time harms for children'.[68]
3.66
Connect Health and Community, a not-for-profit community health
organisation told the committee that its 'youth and family counsellors are
seeing younger children impacted by gaming because of the enticing colours;
rewards and the opportunities games provide to socialise with friends'.[69]
3.67
The Australian Institute of Family Studies (AIFS) told the committee
that loot boxes increase the risk of underage gambling. It stated that 'there
are few controls to prevent underage access to in-game gambling via 'loot
boxes' and other chance-based items'. In addition, the unregulated nature of
'skin gambling' also means that age restrictions are largely absent on
unlicensed 'skin gambling' sites. The AIFS submitted that:
Advertising, both traditional and through peer-to-peer
networks, of other products on these sites, makes eSports, betting in 'skins', 'skin' lottery, casino games and other
forms of gambling easily accessible to underage gamers.[70]
3.68
The AIFS also noted that a lack of understanding of the issue amongst
those 'not versed in gaming culture' means that 'such practices are often
unclear to parents and, therefore, difficult for them to supervise'. It noted
that there are widespread anecdotal reports of minors purchasing in-game items
using their parents' credit cards without their knowledge, for the purpose of
'skins gambling'.[71]
3.69
Adults with impulse control issues are also a significant group amongst
those who experience gambling related harms. Similarly, mental health issues
such as anxiety, and to a lesser extent, depression are significant amongst
those with problem gambling. The VRGF explained that research indicates that
immersion or zoning out occurs with certain types of gambling, and that this
functions as a psychological escape for some people with these issues. However,
the time and money expended is likely to exacerbate gambling related harms, but
the loss of control and cognitive reflection triggered by immersion obscures or
negates any realisation of the issue.[72]
3.70
Connect Health and Community submitted that while much of the discussion
around micro-transactions has focused on young people, there are a range of
individuals including those who are older and have lower levels of computer and
financial literacy who are also at risk of gambling-related harms. It submitted
that:
While these clients are wary of electronic gaming machines in
pubs and clubs they are lured into games such as Candy Crush which encourage
the buying of in-game item using micro-transactions. These include spinning
wheels to win tools to complete the game or additional lives. Spending on these
games can become a problem for people of all ages.[73]
3.71
The RANZCP also noted that gaming disorder has recently been recognised
in the ICD-11 and that individuals with gaming disorder are likely to be
vulnerable to associated addictions including problem gambling, with potential
overlap between gambling and gaming disorders. It submitted that 'as such,
people with gaming and/or gambling disorder may be particularly vulnerable to
developing addictive behaviours towards micro-transactions involving
chance-based items available within the games they play'. The RANZCP stated
that this is particularly, though not exclusively, the case when 'rewards are
important for gameplay, especially when the importance of those rewards renders
the game 'pay-to-win''.[74]
Normalisation of gambling
3.72
For submitters that argued that loot boxes meet the psychological criteria
for gambling, concern was also expressed that loot boxes may operate to
normalise gambling activities to children and young players. The growth and
popularity of loot boxes and simulated gambling 'means that young people are
being exposed, at a minimum, to experiences that mimic gambling' and this 'has
the potential to normalise gambling as a part of the experience of playing
online and video games'.[75]
3.73
The Association of Heads of Independent Schools of Australia (AHISA),
for example, stated that research undertaken for the NSW Government concluded
that 'exposure to gambling at formative stages of development is a risk factor
for the normalisation of gambling as a recreational activity'. In addition, it
was noted that research indicates that 'the scale of the risk of harm to
children and young people in regard to online gambling is significant, given
the extent of children's exposure to simulated gambling games and to in-game
gambling scenarios'.[76]
3.74
Similarly, the AIFS submitted that loot boxes familiarises players, many
of whom are minors, with a gambling activity that is almost identical to other forms
of gambling. It noted that loot boxes coexist with 'lotteries, eSports betting
and other more explicit gambling activities played in virtual currency'. The
AIFS described this process as 'gamblification' and stated that it is analogous
to the processes which exist in the 'context of sports betting, whereby
gambling practices are becoming increasingly normalised as an inherent
component of sports engagement'.[77]
3.75
Connect Health and Community submitted that it has been 'increasingly
concerned about the monetisation of gaming over a period of time' as
'predominately young men [are] graduating from gaming to sports betting and
other forms of gambling'. It stated that 'recent research showed that 29% of
the surveyed young men were placing bets on fantasy sports games weekly'.[78]
3.76
The committee also received evidence from individuals who expressed
concern that loot boxes normalise gambling for children, and that this will
have later negative consequences for them. For example, one submitter stated
that:
My wife is not a gamer, and
has no history with games before or after the lootbox craze. My children have
frequently been able to convince her to pay for random digital prizes in the
hope of getting something they want - and never getting it. My main concern is
that this form of gambling and addiction is being normalised for my children,
so that when they have their own source of income they won't think twice about
spending it on these items.[79]
3.77
Similarly, Ms Stephanie Gray submitted that where children have been
conditioned to view gambling as 'good' through positive reinforcement
mechanisms found in games, the process of transitioning to 'adult gambling'
will be 'easy'. Ms Gray stated:
When people conditioned to think that gambling is good make
the transition to adult gambling (which will be easy considering they've been
doing it in games for so long and see it as a good / fun thing to do, the
prospect of doing it to win money as an adult will also look the same) this
will have severely negative and dangerous effects for the young adult.[80]
3.78
Submitters also noted the impact of gambling-related harms in Australia
'including on household functioning and relationships, health and wellbeing,
and productivity and employment. In more extreme cases, these harms can lead to
family breakdown, family violence and other crimes, mental illness and suicide'.
As such, 'preventing further normalisation of gambling through 'loot boxes' in
video games is a sensible public health measure'. The AIFS stated:
Gambling is recognised as a significant public health and
policy issue in Australia. We submit that normalising gambling to young people
through the provision of 'loot boxes' in online video games constitutes an
additional, avoidable public health risk.[81]
3.79
However, IGEA submitted that 'research on whether loot boxes are harmful
to players and whether the mechanic risks the "normalisation" of
gambling is limited'. It highlighted that a number of researchers have stated
that 'research into simulated gambling is in its infancy' and that more research
needs to be undertaken. IGEA also highlighted that much of the research
currently available relates to social gambling games and practice games rather
than simulated gambling, or loot boxes. It stated:
...the limited amount of research conducted so far predominantly
relates to simulated gambling games, which as described above, are video games
that are very much designed to look, feel and play like traditional gambling
games. Loot boxes are not designed to mimic traditional gambling activities in
the same way that simulated gambling games are, yet even when it comes to these
more overt forms of gambling games, research into "normalisation" is
still inconclusive.[82]
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