The gambling website www.coral.co.uk, seen on 20 February 2018, promoted three different games:
a. The first game was called “Rainbow Riches” and showed an animated image that featured a rainbow, a pot of gold and a leprechaun standing on a yellow road.
b. The second game was called “FISHIN’ FRENZY” and showed an animated image of fishes swimming in the ocean.
c. The third game was called “LUCKY WIZARD” and showed an animated image of a wizard.
The complainant challenged whether the content of ads (a), (b) and (c) were likely to be of particular appeal to children.
Coral Interactive (Gibraltar) Ltd t/a Coral stated that they had conducted an extensive review of their website, whereby all on-site game tiles and promotional material were checked to ensure that they were not in breach of any rules within the CAP Code.
Coral believed that the game in ad (a) ("Rainbow Riches"), which showed an animated image of a leprechaun, was unlikely to appeal more strongly to children and young persons than it would to adults. They believed that the ad was not over the top in its look, or mimicking any particular style that would make the graphics more appealing to a younger audience. Coral Interactive stated that the style was consistent across a multitude of other game tiles and thumbnails, not only on the Coral site, but across the industry for similar products.
Coral stated ad (a) included a trail of gold which was unlikely to appeal to children as it would to adults. Furthermore, they considered that the colour of the green grass and rainbow shown in the ad were unlikely to have particular appeal to under-18s.
Coral stated that ad (b) ("Fishin' Frenzy") was one of the specific examples they identified as potentially having particular appeal to under-18s as part of their internal review. Before the ad was published it included a large fish, which they removed and believed this made the ad less likely to appeal more strongly to under-18s than to over-18s.
Coral stated that ad (b) only showed an undersea setting, which contained small and less detailed images of fish. Coral Interactive stated that the ad's image of fish did not have any specific resemblance to any species that could be identified as being associated with characters from animated films that were likely to appeal to children and young persons.
Coral stated that the image of fish in ad (b) was extremely small and that it was near impossible to make out their specific features. To the extent that features of the fish were visible, they believed that the eyes were in scale with what was seen on various species of fish, and were not exaggerated in any way. They believed that the fish were not smiling and that their mouths followed the curvature of their lower jaw.
Coral stated that the game in ad (c) ("Lucky Wizard") showed an animated wizard, which they believed did not resemble any particular wizard character, and was generic in form. They believed that the animation style was understated, and therefore less likely to appeal to children and young persons. Furthermore, the wizard character was also the sole detail (game name aside) within the game tile, which they believed minimised the association with common fairy tale stories.
Coral stated that the colour of the green grass in ad (c) was unlikely to have particular appeal to under-18s. They stated that the whole background of the ad was green, with both dark and light shades. Furthermore, they believed that the colour of the grass was realistic in its appearance.
Coral stated that the text "Lucky Wizard" in ad (c) was written in a neutral colour and in a generic style, which was unlikely to have particular appeal to under-18s.
The CAP Code stated that gambling ads must not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture. Gambling ads could not therefore appeal more strongly to under-18s than they did to over-18s.
The ASA noted that ad (a) included an animated leprechaun whose face was highly stylised with a large nose, intensely flushed cheeks, big pointy ears and had a big smile showing his large teeth. Furthermore, we noted that the ad included a colourful background showing: a bright yellow road, which was an iconic fictional element in a famous children’s novel; bright green grass; and a vibrant rainbow.
Because of that, we considered ad (a) was likely to appeal more strongly to under-18s than to over-18s.
Ad (b) showed an animated image of fish swimming in the ocean. We noted that the fish were stylised and had large eyes and innocent looking smiles, which we considered depicted them in a cute child-like manner.
Because of that, we considered ad (b) was likely to appeal more strongly to under-18s than to over-18s.
We noted that the animated wizard shown in ad (c) was highly stylised with a large podgy nose, exaggerated cheekbones and had a thick colourful ginger beard with a long moustache with slightly curled tips. Furthermore, we noted that the ad included a colourful background which featured bright green grass along with the name of the game being spelt in gold with magical stars/bolts around it.
Because of that, we considered ad (c) was likely to appeal more strongly to under-18s than to over-18s.
Therefore, because we considered ads (a), (b) and (c) featured animated images that were likely to be of particular appeal to under-18s and were marketing gambling products, we concluded that they breached the CAP Code.
Ads (a), (b) and (c) breached CAP Code (Edition 12) rules 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).
Ads (a), (b) and (c) should not appear again in their current form. We told Coral Interactive (Gibraltar) Ltd to ensure that their gambling ads did not have particular appeal to under-18s.