Ad description
A listing for the “Marvel Contest of Champions” game which had an age rating of 12+ seen on the Apple App Store in August 2025. Text underneath the title of the game stated, “Free - Offers In-App Purchases”.
The listing featured text and images depicting gameplay. Text at the bottom of the page, under a heading “Information”, stated “Price Free” and “In-App Purchases” followed by 10 items and their prices.
Issue
The complainant, an academic researcher in game regulation, who understood that the game contained random-item purchasing (loot boxes), challenged whether the ad was misleading because it omitted material information.
Response
Kabam Games, Inc confirmed that Marvel Contest of Champions contained loot boxes. They said they had overlooked the game description. They had not reviewed it against advertising guidelines. They would adjust it to disclose random-item purchases.
Apple (UK) Ltd said that App Store product pages were viewable before the user downloaded an app and detailed whether it included in-app purchases, specifying optional items available to purchase and setting out how much each item would cost. They also said that such information was clearly labelled under a drop-down, titled ‘In-App Purchases’. They further said that under their App Review Guidelines, developers were required to disclose the odds of receiving each type of item prior to the purchase of apps offering loot boxes.
Assessment
Upheld
The ASA understood that the items received in a loot box were based on chance, and that a player would not know what items they had received in the box until the transaction was completed. CAP Guidance stated that the presence of in-game purchasing, and particularly random-item purchasing (loot boxes), was material to a consumer’s decision to purchase or download a game, especially for consumers with specific vulnerabilities. As such, marketers were required to ensure that advertising for the game made clear that it contained in-game purchasing and, if relevant, that it included random-item purchasing. Mention of random-item purchasing should be immediately next to (or part of) information about in-game purchasing more generally.
Marvel Contest of Champions contained loot boxes that were available to purchase within the game. Although the listing stated “Offers In-App Purchases” and contained a list of 10 such items and their prices, it did not contain any information to indicate to consumers that the game contained loot boxes. We therefore considered the information included in the ad was not sufficient for consumers to understand that the in-game purchases included loot boxes.
Because the ad did not make clear that the game contained loot boxes, which we considered was material to consumers’ decisions to download the game, we concluded that the ad misleadingly omitted material information.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading advertising).
Action
The ad must not appear again in the form complained of. We told Kabam Games, Inc to make clear whether games contained random-item purchasing (loot boxes).
