Ad description

An in-app ad for the mobile app game Legend City, seen in the Airline Commander: Flight Game app on 27 July 2022. The ad was a moving video, which opened with a still image of the pornographic actress Mia Malkova, wearing an off-the-shoulder blouse and leather trousers, looking over her shoulder at the camera in a suggestive manner. To the right of the image were four boxes, two of which contained silhouette images of a woman’s body in sexually suggestive poses and two had padlock symbols in them.

On-screen text stated, “LEGEND CITY … Featured [sic] Mia Malkova”. As the video progressed, on-screen animations depicted a cartoon hand “liking” the main image by tapping a meter to the right of the screen. As the “likes” increased, the meter built up from “min” to “max”, and animations stating “LIKE+1” appeared on the screen. When the meter reached a certain level, the remaining boxes to the right of the screen “unlocked”, revealing further sexually suggestive silhouette images.

The video then depicted a further still image of Ms Malkova, dressed in a revealing cowgirl outfit, as on-screen animations showed money and fireworks floating around her. On-screen text stated, “1ST ANNIVERSARY”, along with links to download the game in the Apple App Store and Google Play. A final still image included another link to the game. Text stated, “Legend City … Limited Log In Gift Packs … Be my man and I will show you the best!”, with a box beneath this wording containing the text “GET”.


The complainant, who believed the ad was overly sexualised and objectified women, challenged whether the ad was offensive and irresponsible.


Shenzhen Yuedong Mutual Entertainment Network Technology Co Ltd said that the Legend City game was intended for players aged 17 and over, which was reflected in its rating in the Google Play Store and the Apple App Store, where it was rated “Mature 17+” and “17+” respectively. They said that when they uploaded the ad they stipulated in the settings that it was not intended for children, but they understood that the "display network" setting in Google Ads could not be age-limited, which they believed could have resulted in the ad being presented to an incorrect audience.

They also said that the silhouettes seen in the ad were intended to represent Ms Malkova, and demonstrate that the game had multiple selectable character images, with a variety of attributes which could be developed by players. Shenzhen Yuedong said that they had not intended for the ad to sexualise Ms Malkova, and had since replaced it, following guidelines outlined in Google’s advertising platforms policy. They said that the replacement ad did not feature potentially sexualised images of women. They also said that they would ensure that future ads would be created with social responsibility in mind, and that they had decided, following the complaint, to pause all advertising into the United Kingdom, while further internal training was provided.

RORTOS, the developer of the app in which the ad was seen, said that the ad had been served in their app by an external system which automatically selected ads from a variety of sources. They said they had no control over which ad source the system selected. They said that they had no relationship with Shenzhen Yuedong.



The ASA considered that the ad depicted Ms Malkova in a sexualised manner. While she was clothed, we considered that the style of clothing, and the pose she assumed, was likely to be seen as sexualised and suggestive. That impression was further reinforced by the images in the boxes next to her on the screen, which contained silhouettes of a woman’s figure in poses which were also sexually suggestive.

Overall, while we regarded the ad as only mildly sexually suggestive, we considered that portraying a woman in that way, for no other reason than to promote an online game, objectified her by presenting her as a sexual object with the sole purpose of titillating viewers.

We acknowledged that the Legend City game was rated for mature audiences. We noted, however, that the ad had been served within another mobile app game, which itself was rated as suitable for all audiences.

While we welcomed Shenzhen Yuedong’s willingness to make changes to their advertising, and to provide further internal training, because we considered that the ad was objectifying, we further considered it was likely to cause serious or widespread offence, included a gender stereotype in a way that was likely to cause harm, and had not been prepared in a socially responsible manner. We therefore concluded that the ad breached the 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.  (Social responsibility),  4.1 4.1 Marketing communications must not contain anything that is likely to cause serious or widespread offence. Particular care must be taken to avoid causing offence on the grounds of: age; disability; gender; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation. Compliance will be judged on the context, medium, audience, product and prevailing standards.

Marketing communications may be distasteful without necessarily breaching this rule. Marketers are urged to consider public sensitivities before using potentially offensive material.
The fact that a product is offensive to some people is not grounds for finding a marketing communication in breach of the Code. 
 and  4.9 4.9 Marketing communications must not include gender stereotypes that are likely to cause harm, or serious or widespread offence.
See Advertising Guidance: “Depicting gender stereotypes likely to cause harm or serious or widespread offence?
 (Harm and offence).


The ad must not appear again in the form complained about. We told Shenzhen Yuedong Mutual Entertainment Network Technology Co Ltd to ensure that their ads were socially responsible and did not cause serious or widespread offence, including by featuring a harmful gender stereotype by objectifying and sexualising women.

CAP Code (Edition 12)

1.3     4.1     4.9    

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