Ad description

An internet display ad for a clothing company, which appeared on, a website hosting children's games, featured three images of women wearing revealing lingerie.  Two images showed the bodies of two women wearing transparent underwear; one image revealed the woman's breasts and buttocks, and the other revealed her breasts and her hand was also placed over her crotch. The third image featured a woman in revealing red lingerie and stockings.


The complainant challenged whether the ad was inappropriately placed, because it would be seen by children.


Lightinthebox (UK) Ltd and did not respond to the ASA's enquiries.



The ASA was concerned by Lightinthebox's lack of substantive 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 provide a substantive response to our enquiries and told them to do so in future.

We were also concerned that had not provided a response.

We noted that two of the images did not feature the women's faces. We considered that the poses were sexually suggestive and provocative and the focus on the breasts, buttocks and groin areas rendered the content of the ad overtly sexual.

The ad had appeared on a website hosting games featuring 'Minions', who were the main characters in the children's film "Despicable Me 2".  We considered that the games were targeted at children and the ad was likely to be seen by children.  We considered that the placement of ads with sexual content on a children's website was harmful and irresponsible and concluded that the ad was in breach of the advertising 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.  (Responsible advertising) and  5.1 5.1 Marketing communications addressed to, targeted directly at or featuring children must contain nothing that is likely to result in their physical, mental or moral harm:  (Children).


The ad must not appear again in its current form.  We told the advertisers to ensure ads placed on children's websites did not feature overtly sexual or sexually suggestive content.  We referred the matter to CAP's Compliance team.

CAP Code (Edition 12)

1.3     1.7     5.1    

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