Background
Summary of Council decision:
Two issues were investigated, both of which were Upheld.
Ad description
An in-game ad and a paid-for social media ad for the mobile app Dialogue: AI Friend Chat Bot:
a. The in-game ad, seen in the Screw Away 3D app on 22 April 2025, featured a video of an AI-generated young female character sitting on a bed. The character spoke directly to the viewer and stated, “I’m your AI girlfriend. I’m always here for you. Whether you’re bored, sad, or just want to chat, I’m always around. I can be fun, supportive, modest or playful. I can be anything you need. Always by your side. Pheon, your AI friend.” Subtitles mirrored the character’s speech. The ad also featured on-screen messages that stated, “Chat with your AI friend We can discuss anything you want [face with hand over mouth emoji]”.
b. The paid-for Tumblr ad, seen on 9 April 2025, featured a video of an AI-generated female character sitting on a bed, playing with her hair. The character addressed the viewer and delivered the same speech as in ad (a), with matching subtitles and on-screen messages.
Issue
The ASA received two complaints.
- One complainant challenged whether ad (a) portrayed someone who seemed to be under 18 years of age in a sexual way.
- One complainant, who believed ad (b) presented the character as a sexual object, challenged whether it was offensive and irresponsible.
Response
Pheon Inc said the ads had been live for only a short period and would not be run again.
They had created the ads in line with their internal Ad Content Policy, which required that individuals be depicted as aged 18 or over, that bodies be fully covered, that no explicit outfits be shown, and that there be no implied sexual content. However, they acknowledged the complainants’ concerns and said they had conducted a full internal review of their advertising. As a result, they had introduced stricter internal approval processes to ensure future campaigns aligned with their stated values of safety and responsibility.
Moloco, the ad network that served the ads, said they had determined that the ads violated their policies on adult content. They confirmed that the ads were no longer running.
Assessment
1.Upheld
The CAP Code stated that marketing communications must not portray or represent anyone who was, or seemed to be, under 18 years of age in a sexual way.
The ASA considered that the character’s youthful facial features and voice, slim frame, smooth skin and mannerisms were likely to lead many viewers to interpret her as being under 18 years of age. We further considered that her brightly coloured, pyjama-style outfit contributed to her childlike presentation in the ad.
We acknowledged that the ad was not explicit. However, the bedroom setting, the character in her pyjamas and her behaviour in tilting her head to the side, leaning forward and addressing the viewer directly gave it a sexually suggestive tone. In that context, we considered the references to being “your AI girlfriend”, “playful” and “anything you need” to imply that she was proposing a flirtatious or romantic relationship. We further considered the text “We can discuss anything you want” in combination with a face over mouth emoji hinted at sexual content.
Because the ad depicted a person who appeared to be under the age of 18 in a sexual way, we concluded that it was irresponsible and breached the Code.
Ad (a) breached CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.8 (Harm and offence).
2.Upheld
Ad (b) featured a character kneeling on the bed with her legs wide apart as she leant forward to address the viewer directly. She was wearing a low-cut vest top and brief-style shorts. She was shown running her hands through her hair and inclining her head in a coquettish manner as she spoke. Although the ad was not explicit, we nevertheless considered that those features made it sexually suggestive in tone.
The character described herself as “your AI girlfriend” and “always here for you”. She also said she could be “anything you need”. The text “We can discuss anything you want” in combination with a face over mouth emoji hinted at sexual content. We considered that the character was presented as being available to fulfil the viewer’s emotional or sexual needs on demand.
We considered that, in combination, those visual and spoken elements reduced the character to a sexual object for the viewer’s gratification. Because the ad included harmful gender stereotypes and was likely to cause serious offence, we therefore concluded that the ad was irresponsible and breached the Code.
Ad (b) breached CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.9 (Harm and offence).
Action
The ads must not appear again in the form complained of. We told Pheon Inc to ensure that future ads did not portray anyone who seemed to be under 18 years of age in a sexual manner. We also told them to ensure their ads were socially responsible and did not cause serious or widespread offence by harmfully stereotyping women as sexual objects.
