A promotion on a website, www.888.com, for an online casino game was presented in a comic-book style format. It featured images of Spiderman and text stated "THE AMAZING SPIDER-MAN".
The complainant challenged whether the ad was irresponsible, because it was likely to be of particular appeal to children.
Cassava Enterprises (Gibraltar) Ltd, trading as 888.com (888.com), said the ad did not predominantly appeal to those under 18 years of age. Spiderman had an ongoing appeal to those over 18 and this was demonstrated by recent movies that appealed to over-18s which featured "comic" characters. They said Spiderman was a comic book that originated in the late 60s and grew to popularity throughout the 70s and 80s and that those who grew up reading the comics could relate to the stories and images portrayed in the slot machine bonus rounds.
It was not possible for under-18s to play the game for real money in their casino, as all members had to provide their name, address and date of birth, accept the Terms and Conditions and confirm that they were over 18. 888.com had developed a host of background checks and document procedures to ensure that they only permitted the availability of their real game software to over-18s. The ad appeared on their website where there was a clear warning that only players that were aged 18 or over could play for real money.
The ASA understood members had to confirm they were aged 18 or over before they could register to play the game. However, we noted the ad appeared on the website, which was accessible to visitors, regardless of whether they were members. The Code stated that marketing communications for gambling products should not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture. We acknowledged that Spiderman appealed to some adults, but considered that the depiction of the popular comic book character was likely to have particular appeal to children and young people. We therefore concluded that the ad breached the Code.
The ad breached CAP Code (Edition 12) rules 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Social responsibility), 16.1 16.1 Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited. 16.3 16.3 Marketing communications must not: and 16.3.12 16.3.12 be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture (Gambling).
The ad must not appear again in its current form. We told Cassava Enterprises (Gibraltar) Ltd, trading as, 888.com, not use images that were likely to be of particular appeal to children or young people in future gambling ads.