An ad for the film It Chapter Two, heard between songs on the Classical Lullabies playlist on Spotify on 28 August 2019, featured a voice-over from the character Pennywise the Dancing Clown which stated, “For 27 years, I dreamt of you. I craved you. Oh I missed you”. Another of the film’s characters then stated “Pennywise” and the noise of a number of laughing clowns was heard, before another voice-over stated, “It Chapter Two. In cinemas September 6”.
The complainant, who played the Classical Lullabies playlist for their child, challenged whether the ad was inappropriately targeted.
Warner Bros. Entertainment UK Ltd (Warner Bros) said the ad reflected themes of the It Chapter Two film and was intended to invoke feelings of suspense in the listener. They said the ad might have been perceived as mildly scary, but it avoided violence, offensive language, gore and elements of the film which might have been considered overly scary. Warner Bros said the ad could only be heard by logged in users of Spotify. They intended to attract the attention of those between 18 and 44 years of age, which they considered a relevant demographic for the film. They used the parameters “Age is 18-44” and “Real Time Genre is not Children” (also known as “No Kids Music”) to ensure the ad was appropriately targeted. Spotify said they believed the parameters used by Warner Bros to target the ad were appropriate and that they did not believe the playlist was designed primarily for children.
The ad began with a cinematic drum noise and a crescendo of high-pitched percussive sound, which the ASA considered immediately created the feeling of suspense. The sound continued through the ad, while the voice of the film’s villain Pennywise stated, “For 27 years, I dreamt of you. I craved you” in a deep tone. He then shouted, “Oh I missed you” in a loud and desperate manner as the ad built to a climax with a sharp snap of a second drum, at which point another of the film’s characters stated “Pennywise”, and the sound of laughing clowns followed.
We considered those elements meant the ad was likely to cause distress to young children, and that it should have been appropriately targeted to avoid the risk of them hearing it.
The ad was heard by the complainant between songs on the Classical Lullabies playlist. Given the name of the playlist – which included the songs “Children’s Music No.1: I. Lullaby”, “5 English Nursery Tunes” and “For Children Vol. 1” ? we considered that the playlist was designed primarily to be played to and therefore likely to be heard by young children. Spotify provided no explanation as to why an ad targeted using the parameter “Real Time Genre is not Children” had been played during a playlist designed to be heard by young children.
We therefore considered that although Warner Bros had taken steps to target the ad responsibly, because it appeared around content that was likely to be heard by young children, who were likely to be distressed by it, the ad had been inappropriately targeted. 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) and 4.2 4.2 Marketing communications must not cause fear or distress without justifiable reason; if it can be justified, the fear or distress should not be excessive. Marketers must not use a shocking claim or image merely to attract attention. (Harm and offence).
We told Warner Bros. Entertainment UK Ltd to ensure that future ads that were unsuitable for children did not appear in media which was designed primarily for children.