Ad description
A paid-for X (formerly Twitter) ad for the “Blackjack 21: Blackjackist” game, seen on 2 April 2025. The caption stated “No annoying notifications. No purchases. Just. Good. Old. Blackjack”.
Issue
The complainant, an academic researcher in game regulation, who understood that the game contained in-game purchases, including random-item purchasing, challenged whether the ad was misleading.
Response
KamaGames Ltd t/a Blackjackist said that “No purchases” referred to the fact that players could enjoy the full game experience without making any purchases. They explained that “chips” were earned in-game and gifted daily, which allowed for continuous play without requiring a purchase to be made. Because players received chips through gameplay and daily gifts, purchases were optional, rather than essential. They re-iterated that in-game purchases did not affect the ability to play or progress within the game.
They said that there were no loot boxes or random-item purchasing mechanisms. They acknowledged that the CAP Guidance stated that advertising for games featuring in-game purchases should make the presence of such purchases clear if material to consumer decisions. However, they said that the claim was made in the context of gameplay experience where purchases were not required. They believed the ad did not imply that purchases were unavailable, but rather that they were not necessary to play the game. They confirmed that the ad had been withdrawn.
Assessment
Upheld
CAP Guidance stated that the presence of in-game purchasing, and particularly random-item purchasing, was material to a consumer’s decision whether or not to purchase or download a game, especially for consumers with specific vulnerabilities. As such, marketers should ensure that advertising for the game made clear that it contained in-game purchasing and, if relevant, that it included loot boxes.
The ASA considered that consumers would understand the claim “No purchases” to mean that the game Blackjackist did not contain any in-app purchases. We considered the presentation of the claim in the ad, which appeared together with the claims “No annoying notifications” and “Just. Good. Old. Blackjack” reinforced the impression that the game did not contain any in-app purchases and was purely focused on gameplay.
We understood, however, that Blackjackist contained virtual currency (“chips”) as well as items such as “lottery tickets” and “free spins”, which were available to purchase with real money. We further understood that those items provided players with rewards that contained an element of chance. We also noted that Blackjackist’s Google Play Store page stated that the game contained in-game purchases, including random items.
We acknowledged that KamaGames believed their ad did not imply that consumers could not make purchases within the game, rather that it was unnecessary to purchase them in order to play. However, we considered the ad, in particular the text “No purchases”, gave the impression that the game did not include any purchases whatsoever, regardless of whether they were needed to play the game.
Because the ad did not make clear that the game contained in-game purchases, including random-item purchases, we concluded that the ad was misleading.
The ad breached CAP Code (Edition 12) rule 3.1 (Misleading advertising).
Action
The ad must not appear in the form complained of. We told KamaGames Ltd t/a Blackjackist to ensure that ads for the “Blackjack 21: Blackjackist” game did not mislead consumers by claiming that they did not contain in-game purchases, including random-item purchases, if that was not the case.
