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ASA Ruling on Universal Pictures International UK & Eire Ltd

Universal Pictures International UK & Eire Ltd

1 Central St. Giles
St. Giles High Street


31 December 2014


Internet (video)



Number of complaints:



Mediacom Holdings Ltd

Complaint Ref:



A pre-roll ad on YouTube for the film ”As Above, So Below” seen before videos featuring characters iBallisticSquid and Stampylonghead, from the game Minecraft. The ad opened with images of dark tunnels in the Catacombs in Paris that were lined with skulls and bones. The ad then showed the characters exploring the tunnels and getting lost, followed by a sequence of shots of a distorted face with screams in the background. Other scenes featured a body hanging on a noose, a male character being thrown into a burning car and another male character attached to a rope being pulled down a vertical shaft.


The complainant, whose eight-year-old child saw the ad and became distressed by it, challenged whether the ad had been responsibly targeted because it appeared before videos which they believed would appeal to children.

CAP Code (Edition 12)


Universal Pictures International UK & Eire Ltd responded that ”As Above So Below” was a thriller horror film that was rated "15" by the British Board of Film Classification. They stated that in order to convey the theme and storyline of the film, the ad contained some moderately alarming scenes.

They said that they worked closely with their agency and YouTube to ensure that the ad was targeted at the correct audience. Despite the "15" rating, their agency put an agreement in place with YouTube that by using demographic targeting, which was based on the date of birth registered to the user accounts that were logged in, only users aged 18 years or above would be targeted. Universal Pictures stated that their agency also instructed YouTube to implement a secondary filter targeting users whose interests were films within the horror, fantasy, sci-fi and action genres. They said that, in the course of the investigation, they had been informed by YouTube that it was possible for users to be served the ad without being signed in to an account through inferred targeting. This meant that a user, who was not signed in to YouTube with a specified age, would be served ads that were appropriate to the profile established by the user's viewing history on the device used.

Universal Pictures did not consider that the ad was irresponsibly targeted and therefore in breach of the CAP Code, given that they took all reasonable measures to ensure the ad had been targeted at viewers who were 18 years old or above. They said that the YouTube platform was not targeted at young children given the minimum age requirement for registration of an account was 13 and that the content of the ad was not unduly shocking or distressing for the intended audience.

Universal Pictures stated that they regretted the ad had been seen by an eight-year-old and appreciated that the content was not appropriate for that age group.

YouTube responded that the ad was not in violation of their applicable advertising polices and that they were not aware of any direct complaints regarding the ad. They stated that under terms and conditions agreed to by Universal Pictures, it remained their responsibility to ensure that they abided by the applicable law and regulations, including the CAP Code.



The ASA considered that the imagery and effects featured in the ad reflected the theme and premise of the film. We acknowledged that the content of the ad was not excessively shocking for viewers who were 18 years old and above and therefore was unlikely to cause distress to those viewers the advertiser had intended to target. However, we considered certain scenes in the ad, in particular those of the distorted and menacing faces accompanied by screaming, the man hanging on a noose and the male character being pulled into the burning car, would be likely to cause distress to young children.

We noted Universal Pictures' explanation of the measures that they had instructed YouTube to put in place, by using demographic targeting with the criteria being viewers aged 18 and above, and also implementing a secondary filter to ensure that the ad would be served on those who expressed an interest in horror and fantasy themed films.

We understood that a specific YouTube account had not been signed in to and that the safety mode had been activated at the time the complainant's son saw the ad. We also understood that the complainant's son had not been able to skip the ad. We noted that the ad appeared before YouTube videos featuring Minecraft characters, Stampylonghead and iBallisticsquid. We understood that although the game Minecraft did not have an audience that comprised exclusively children, the game was very popular among them. On this basis, we considered that these videos were highly likely to be of particular interest to children.

Although we noted the measures that Universal Pictures had taken in order to ensure that the ad would only be shown to an appropriate audience, we considered that given the possibility that viewers who were not signed into a YouTube account with particular viewing history, they could still be served the ad. Also, in this instance the ad appeared before videos that we considered were likely to appeal to young children, and therefore the ad had not been targeted appropriately. We concluded that the ad was in breach of the Code.

The ad breached CAP Code (Edition 12) rules 1.3 (Social Responsibility) and 4.2 (Harm and Offence).


We told Universal Pictures International UK & Eire Ltd to ensure that future ads that were unsuitable for viewing by children were appropriately targeted.

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For advice and training on the Advertising Codes please visit the CAP website.

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