Marketing of Violent Entertainment to Children

Following is a letter from Ralph Nader and Commercial Alert to Robert
Pitofsky, Chairman of the Federal Trade Commission, regarding the
marketing of violent entertainment products to children.

June 22, 1999
Robert Pitofsky
Federal Trade Commission
600 Pennsylvania Ave.
Washington, DC 20580
RE: Marketing of Violent Entertainment to Children

Dear Chairman Pitofsky:

On June 1, President Clinton instructed the Federal Trade Commission
(FTC) and the Department of Justice to study the advertising and
marketing of violent entertainment products to children. In his
speech, the President noted that "Every parent knows what response a
commercial for sugar cereal or the latest Star Wars toy will get from
their children. People advertise because it works. They want that
product and, one way or the other, they're determined to get it."
Advertising, the President said, has "the power to egg children on and
lure them in."
The President is right -- advertisers exercise a great deal of
influence over our children. That is why this study is very
We all know what the advertisers say in public-- that they are merely
providing "information" to children, that parents make the real
decisions, and so forth and so on. It is crucial that the FTC gets at
the truth behind the marketing of violence to children. It must expose
how entertainment industry operatives talk to one another when they
target the nation's children, not just how they speak to the public
when the cameras are running. This will require digging.
The FTC will have to use its subpoena power aggressively to compile
internal corporate memoranda, marketing studies and other evidence of
how television, motion picture, video game, music, and in-school
advertising companies market violent entertainment products to American
children. Parents are entitled to know about the designs that
corporate marketing departments have on their children. They are
entitled to know about the strategies and seductions these corporations
deploy. They need to know these things to protect their children. And
this information could form the basis for further legislative or
regulatory action on the marketing of violent entertainment products to
It is especially important that the FTC investigate corporate
strategies and influences such as these:
Channel One and its advertisers. Channel One is a marketing company
that uses the schools to deliver advertising to captive audiences of
children. It promotes itself to advertisers as the "news show that
delivers more tween viewers than any other programming that you can
buy." Currently, the MTV-like program is shown to about eight million
middle, junior high and high school students in about 12,000 schools.
In these schools, students spend the equivalent of about one class week
each year watching Channel One, including one full school day just
watching ads. According to Jim Metrock of Obligation Inc., Channel One
has broadcast commercials for violent movies and television including
The Mummy, Steven King's The Shining, Buffy the Vampire Slayer, and The
Quest. This list is incomplete because Channel One refuses to make its
programming available to the public. Channel One has repeatedly played
Blockbuster Video ad which showed a child collapsing after five days of
non-stop video game playing. Did that advertisement contribute to the
use of violent video games by children? The FTC should require Channel
One to disclose all entertainment products that it has displayed,
featured, played, or advertised to its vast audience of captive
schoolchildren. Parents ought to know what entertainment products are
advertised to their children while they are in school. Enclosed is
testimony on Channel One from a hearing before the Senate Committee on
Health, Education, Labor and Pensions.
Which advertisers support violent television programming. The free
market is based upon the principle of choice. Buyers are supposed to
be able to make informed choices about which companies and products
they want to support. The market doesn't work today in regards to the
marketing of violence to children because parents don't have they
information they need.
We urge the FTC to fill this gap so that the market can work. The FTC
could tally the average number of televised violent acts by show and by
sponsor, and publish statistics regarding which shows are the most
violent, and which companies sponsor the most violent TV shows. This
would help parents express their informed preferences in the
marketplace in regards to the networks and sponsors for their violent
programming. Parents could learn of the most violence-associated
brands of peanut butter, soap, toothpaste, hamburgers, soda, chewing
gum, etc., and could make their purchasing decisions accordingly.
The use of psychological techniques in marketing violent entertainment
products to children. Advertisers employ the tools of psychology to
design the ad campaigns with which they barrage impressionable
children. The FTC should investigate precisely how they do this -- and
how they enlist children in the process. Parents need to know the
strategies and wiles by which entertainment corporations are targeting
their children -- and they need to know who is responsible. What
studies have entertainment companies done to enable them to tap into
and manipulate the psyches of children? Such information could be of
great use to families that wish to give their children tools to defend
themselves against these corporate marketing strategies. Attached is a
copy of our book Children First: A Parent's Guide to Fighting Corporate
Predators, which discusses this subject in some detail.
Heightening and preferential selection of violent content. Do
entertainment companies purposefully heighten or modulate the violent
content of media to increase the number of children who watch or
purchase their product? If so, how? Five years ago, The Wall Street
Journal reported on the story of gangster rapper Lichelle "Boss" Laws:
"It wasn't until Ms. Laws acquired the flavor' -- entertainment
industry jargon describing the style found among the youth from
America's mean streets -- that she was able to land a recording
contract. I tried the straight-up nice girl' approach, she says, and
it didn't work.' So she raps songs such as A Blind Date With Boss,' in
which she acts out the seduction and murder of her date, a macho
Advertiser influence on violent television programming. To what extent
have advertisers encouraged violent television programming directly or
indirectly -- through steering their support to television shows with
substantial violent content, or, for example, by complaining when the
programming does not appeal to the lowest common denominators among
young viewers.
Furthermore, we urge the FTC to study the market for violent
entertainment products and evaluate evidence that these violent
products are a classic case of market failure, in that the consumption
of violent entertainment products may create social costs that are not
comprehended by the market or the price mechanism. Such costs could
include, for example, heightened levels of crime, violence, aggression,
and desensitization to violence. In his book Channeling Violence: The
Economic Market for Violent Television Programming, James T. Hamilton
argues that "television violence is fundamentally a problem of
pollution" -- that violent television programs cause externalities
(e.g., harm to children) which are not taken into account by market
forces. The FTC should expand this analysis to include other types of
entertainment products, including movies, music and video games.
Hamilton writes that "If television violence is akin to pollution, then
policies designed to deal with the negative externalities generated by
pollution are an obvious place to start in considering how to deal with
televised violence." The FTC should consider and evaluate such
policies as a part of its efforts to "look at whether more should be
done" by the FTC regarding the marketing of violent entertainment
products to children.
The FTC should review the European experience related to advertising to
children. Some European nations restrict advertising to children. For
example, Sweden and Norway prohibit television advertising directly
targeting children below 12 years of age. Of course, in the United
States, children have no such protections. We also attach a list of
experts on the subjects of marketing to children and media violence
whom the FTC ought to interview for its study.
Congress has granted broad subpoena powers to the FTC to investigate
corporate conduct. We hope that the FTC will use its powers in the
service of parents and families, to uncover how the entertainment
industry sells its violent entertainment products to children.


Gary Ruskin Ralph Nader

<--------------------Letter ends here--------------------

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Gary Ruskin | Commercial Alert
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