Two paid-for Facebook post by the developer Playrix for two apps:
a. A paid-for post for Homescapes, seen on 31 March 2020, included the caption “Think you can do better?”. The ad included a video which showed three cartoon characters of a man, a woman and a burglar. The video showed pins being pulled out in an attempted to unite the man and woman without meeting the burglar. Throughout the video, on-screen text at the top stated “Help her escape!”. At the start of the video, on-screen text at the bottom stated “Not all images represent actual gameplay”.
b. A paid-for post for Gardenscapes seen April 2020, included the caption “You’ll want to play 24/7!”. The ad included a video which showed two cartoon scenarios. The first scenario showed a man floating at the base of a tower filling with water. Above the man, two pins held money and lava in place. In the second scenario, the man was shown separated by pins from a dog, lava and money. Throughout the video, on-screen text stated “HOW TO LOOT?”. At the start of the video, on-screen text at the bottom stated “Not all images represent actual gameplay”. At the end of the video, on-screen text was displayed which stated “Gardenscapes” and “ONLY 5% CAN SOLVE THIS”.
IssueSeven complainants, who believed the ads’ content was not representative of the Homescapes or Gardenscapes games, challenged whether the ads were misleading.
PLR Worldwide Sales Ltd t/a Playrix said that the content seen in the ads was included in their games and that the content represented part of the gameplay itself. Playrix believed consumers would take from the ads that the games contained the content seen, as well as similar content involving similar characters. Also that the games would have the same design and mechanics, alongside similar gameplay. They believed that the ad appealed to the logic and problem-solving skills required to win during the games. They also believed consumers may have thought that their games were not straightforward ‘match-three’ titles, but would include a variety of mechanics.
Playrix said their Homescapes and Gardenscapes games contained thousands of levels, where each level contains one ‘match-three’ style game. In April 2020, Gardenscapes had 5,895 levels and Homescapes had 4,160 levels. However, they said only a very small percentage of their players reached those levels; for Homescapes, they said that percentage was around 0.03% of users. Playrix said most users finished their journey near the start of the game. For example, their said only around 45% of players achieved the level 20, and around 18% achieved the level 100. Playrix said that the gameplay shown in the ads were ‘mini-games’ that were first available to play at the beginning of April 2020, but on more distant levels only. They said that they had since changed the games so that the same gameplay as shown in the ads was available towards the beginning of the Homescapes and Gardenscapes games. Playrix therefore believed that most players were able to dedicate significant amount of their in-game time to that experience.
In April 2020, Playrix said there were around 10 such mini-games in Homescapes. They said that at that time the mini-games were usually available once every 20 levels. Playrix said their games were far more complex than ‘match-three’ type games. They said they contained a number of elements: an unfolding storyline which involved the renovation of a house or a garden; ‘mini-games’ (as featured in the ads); and ‘match-three’ style games. They said the latter was the only tool to move on in the storyline and was not the core gameplay. They said a player’s goal was to follow the storyline and restore and decorate their house or garden though different mechanics.
Playrix provided a recording which showed the game being played and a breakdown of the time spent on each element of gameplay. Playrix also provided examples of the ‘match-three’ games and of the mini-games featured in the ads. Playrix believed the mini-games featured in the ads were a unique element of their games compared to other similar companies, which was the reason they wished to feature them in the ads. They said there were time limits to the Facebook ads, which meant they were not able to feature the variety of mechanics and elements of the gameplay in their games.
Playrix said they therefore informed consumers that the ads did not present all the games’ gameplay by showing the text at the bottom of the ads, and by placing screenshots and comprehensive videos from the games on the stores’ web pages so that the players may see them just before installing the games.
The ads each showed a game where the aim was to choose actions in a certain sequence. The ASA considered consumers would understand from the ads that the content featured was representative of the Homescapes and Gardenscapes games overall.
We acknowledged that the ads included text which stated “Not all images represent actual gameplay”, and we therefore considered consumers would understand that the exact gameplay featured may not necessarily be available. We nevertheless considered consumers would expect the Homescapes and Gardenscapes games would consist of a similar problem solving style. However, we understood that the Homescapes and Gardenscapes games in large part consisted of gameplay which involved a storyline about the renovation of a cartoon house or garden and ‘match-three’ style puzzle games.
We understood users would play a significant amount of content which was of a different style in order to access the gameplay featured in the ads. We considered that the time limits placed on Facebook ads were of a sufficient length that the advertiser was able to feature content that was reflective of the overall games. Because the ads were not representative of the games they were purported to feature, we concluded that they were misleading.
The ads breached CAP Code (Edition 12) rules 3.1 3.1 Marketing communications must not materially mislead or be likely to do so. (Misleading advertising), 3.9 3.9 Marketing communications must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify. (Qualification) and 3.11 3.11 Marketing communications must not mislead consumers by exaggerating the capability or performance of a product. (Exaggeration).
The ads must not appear again in the form complained of. We told PLR Worldwide Sales Ltd t/a Playrix to ensure that their future advertising presented gameplay which was representative of the games they advertised.