Summary of Council decision:

Two issues were investigated, both of which were Upheld.

Ad description

An in-game ad for the mobile app game “Brain Story: Tricky Puzzle” seen in the “Gallery: Coloring Book & Decor” and “Alice’s Resort – Word Game” Google Play mobile apps on 28 December 2021 featured an animation of two women wearing Christmas-themed outfits playing rock, paper, scissors. Cropped close-ups of one of the character’s breasts and buttocks were then presented as options on screen; a mouse pointer appeared and clicked on the buttocks, causing one of the women to slap the other’s buttocks twice while an accompanying voice-over stated, “Play now”.

The ad then cut to an animated depiction of a man and woman preparing to play rock, paper, scissors. A mouse clicked the box corresponding to scissors and the characters revealed their choices: the woman had chosen paper while the man had won with scissors. The woman was then depicted with her arms upright tied to the ceiling with her bra partially exposed, sitting with her bare feet up on a table, giggling while her feet were tickled with a paintbrush. The man was then shown to win a second round of the game and cropped close-ups of the woman’s buttocks and breasts were then presented as options on screen while a mouse pointer hovered between them as if choosing which to click.


The complainant challenged whether the ad:

1. which they believed objectified and sexualised women, was offensive and irresponsible; and

2. had been irresponsibly targeted.


ABI Global Ltd did not respond to the ASA’s enquiries.

The ASA also contacted Beresnev Games and WePlay Word Games, the developers of the apps in which the ad was seen, but they also did not respond to our enquiries.


The ASA was concerned by ABI Global Ltd’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule  1.7 1.7 Any unreasonable delay in responding to the ASA's enquiries will normally be considered a breach of the Code.  (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.

1. Upheld

The ASA noted that the ad’s female characters were very similar in appearance, with elongated limbs, small waistlines, large breasts, and tight, short outfits that partially exposed their large buttocks. We also noted that the scenario depicted was a game of chance in which losers had to perform a sexually suggestive forfeit and that the nature of that forfeit was determined by the player’s choice between cropped close-up shots of the characters’ breasts, buttocks or groin.

We considered that those elements of the ad depicted the female characters as sexual objects, stripped of any agency or personality in their portrayal as entirely obedient to the player’s commands. We considered that this objectified and stereotyped women by presenting them as objects in a scenario designed for the purpose of titillating viewers.

We concluded that the ad was likely to cause serious and widespread offence, and included a gender stereotype in a way that was likely to cause harm. We therefore concluded that the ad was irresponsible and breached the Code.The ad breached CAP Code (Edition 12) rules  1.3 1.3 Advertisements must comply with the law and broadcasters must make that a condition of acceptance.  (Social responsibility),  4.1 4.1 Advertisements must contain nothing that could cause physical, mental, moral or social harm to persons under the age of 18.  and  4.9 4.9 Advertisements must not condone or encourage violence, crime, disorder or anti-social behaviour.  (Harm and offence).

2. Upheld

We considered that, because this specific ad was irresponsible and likely to cause serious or widespread offence, it was not suitable to be featured in any game, regardless of whether the advertiser had taken steps to target it away from specific audiences.Notwithstanding that, we understood that the advertised game, “Brain Story: Tricky Puzzle”, included gameplay similar to that depicted in the ad. We considered that consumers playing unrelated games, or viewing other unrelated content online, would not expect to be served an ad for a game which featured adult content. As such, we expected ABI Global to have targeted any ad for the game responsibly, including limiting the audience to users aged 18 years and over. This should have been achieved using age verification measures including interest based targeting factors that described an adult audience and excluded a child audience. However, the ad was seen in two games rated as PEGI 3 – meaning they were considered suitable for all age groups – which could be downloaded by children. Because the advertiser had not provided us with evidence that they had taken appropriate action to minimise the risk of under-18s being served the ad, we concluded that the ad had been irresponsibly targeted.

On that point, the ad breached CAP Code (Edition 12) rule  1.3 1.3 Advertisements must comply with the law and broadcasters must make that a condition of acceptance.  (Social responsibility).


The ad must not appear again in its current form. We told ABI Global Ltd to ensure that their ads were socially responsible and did not cause serious or widespread offence, including by objectifying women. We also told them to ensure that they did not present gender stereotypes in a way that was likely to cause harm and to ensure that their ads were responsibly targeted. We referred the matter to the CAP’s Compliance team.


1.3     1.7     4.1     4.9    

CAP Code (Edition 12)

1.3     1.7     4.1     4.9    

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