Statement of Chairman Robert Pitofsky on FTC Youth Violence Report

On June 1 of last year, President Clinton asked the Federal Trade Commission (in cooperation with the Department of Justice) to answer two important questions. Parallel requests were received from many in Congress. Among many others, Senators McCain, Hatch, Brownback, Hollings and Lieberman indicated interest and support for the project. The questions were:

• Do the movie, music recording and computer game industries market to young people products that contain violent content in a way that undermines the ratings they themselves apply to their products?

• If so, is that target marketing intentional?

For all three industry segments, the answer is yes to both questions. Target marketing to children of entertainment products with violent content is pervasive and aggressive. Today, we submit our report to the President and to the Congress.

While rating systems vary, all three entertainment segments maintain systems that designate certain material as warranting parental control, or as inappropriate for young people.

Nevertheless, companies in each entertainment segment routinely end run, and thereby undermine, these parental warnings by target marketing their products to young audiences. We examined marketing plans and programs for most of the best-selling video games rated Mature for violence in 1999.

There were too many music CDs and movies to look at each one, so we selected on the basis of best-selling products or those most likely to appeal to young people.

Our review provides a telling snapshot of each industry's practices.

• Of 44 movies rated R that we examined, 35 or 80 percent, were marketed to youngsters under 17. One document states, "Our goal was to find the elusive teen target audience and make sure everyone between the ages of 12 - 18 was exposed to the film." Another document dealt with a movie that was a sequel to one rated R, where the marketing group expected the sequel to be R rated as well. The document said, "there is evidence to suggest that attendance at the original movie dipped down to the age of 10. Therefore, it seems to make sense to interview 10 to 11 year-olds as well. In addition, we will survey African-American and Latino movie goers between the ages of 10 and 24." It occurred to us that some might say that if you look at thousands of documents, you are bound to find one that is extreme. So we reviewed the entire practice of testing young audiences, and found that of the 44 movies reviewed, 33 used young people under17 in their market testing and 8 tested audiences that included 12 year-olds. Another document spoke of targeting youth groups such as Boy Scouts, Girl Scouts, and 4-H Clubs.

• Of 55 music recordings with "explicit content" labels, all 55 were marketed to kids under 17. Fifteen, or 27 percent, expressly identified teenagers as part of their target audience. One such plan said its "target audience" was "12 - 34."

While the marketing documents of the remaining forty "explicit content" recordings did not expressly state the age of the targeted audience, they described the same methods of marketing. For example, music is aggressively marketed on MTV where demographic data show that children under 17 are often close to half of the audience.

• Of the 118 of the electronic games with a mature rating for violence - and some of these games display astonishing levels of violence - 83 of those games, or 70 percent, were targeted to children under seventeen. One such plan referred to a target market as "males 17 - 34 due to M rating (the true target is males 12 - 34)." A couple of other marketing plans even referred to a target audience as young as 6 and 8. Finally, a document recommends advertising to a primarily male audience 12-17 because "the younger the audience, the more likely they are to be influenced by T.V. advertising."

Our study found that most retailers made little effort to restrict access to these age-restricted or labeled products and, as a result, young people have easy access to these materials. Our surveys found that just under half the movie theaters admitted young people ages 13 to 16 to R rated films even when not accompanied by an adult, and when the theaters did check on age, the young people had strategies that easily circumvented the current restrictions. Unaccompanied children ages 13 to 16 were able to buy both "explicit content" recordings and mature - rated electronic games 85 percent of the time.

The Commission did not independently survey the issue of whether there is a causal connection between exposure to violent entertainment materials and violent behavior.

Rather we reviewed the literature and found that scholars and observers generally agree that exposure to violent materials alone does not cause a child to commit a violent act. Exposure to violent materials probably is not even the most important factor. It is nevertheless a valid cause for concern. Exposure does seem to correlate with aggressive attitudes, insensitivity to violence and an exaggerated view of how much violence occurs in the world.

Since the President initiated this project in June 1999, all three industry segments have modified their rating systems or their review of target marketing in constructive ways, but each has a long way to go to develop an adequate system of giving parents control of the entertainment materials their children are exposed to. Our report offers three suggestions for more effective self-regulation: (1) establish or expand codes that prohibit target marketing to underage audiences, and impose sanctions for violations; (2) increase compliance with rating restrictions at the retail level; and (3) increase parental understanding and decrease confusion about the ratings and labels.

Let me emphasize that this review and publication of this report, and proposals to improve self-regulation, are not designed to regulate or even influence the content of movies, music lyrics or electronic games. The First Amendment generally guarantees that creative decisions about content be left to artists and their distributors. Rather the idea here is to encourage the industries through self-regulatory initiatives to help parents choose entertainment they deem appropriate for their children.

Responsible people in the movie, music and video game industries, and in related trade associations, recognize that there is widespread concern about exposure of young people to violent entertainment materials and have committed to rate and label materials that may be inappropriate for a young audience. Our studies show that parents want and use rating information, and many respond approvingly to the rating systems in place. But industry documents demonstrate in the clearest terms that many companies in those entertainment sectors routinely market their materials to an underage audience regardless of the ratings applied. These industries can and should do better.