The recent discussion concerning the ESA's desire to have its rating organization, the ESRB, evaluate game content for the iTunes App Store brings a number of questions to mind:
Having watched how corporations, lobbyists and their related entities do business for some time now, I'm too jaded to believe that ESA/ESRB wants to jump into rating App Store games for the good of society or because it's the right thing to do. This would, after all, be a significant commitment of ESRB resources. Generally such things happen because there is revenue to be made or there's power to be grabbed.
Despite its present chaotic nature, the App Store is a rising star in the game space. Getting in on the ground floor would be a coup for the ESRB. Apple has a lot of money, too, and the ESRB is paid a fee by the developer/publisher for each game it rates. Despite my cynicism, ESRB spokesman Eliot Mizrachi told me that it's not about the Benjamins:
ESRB is a non-profit organization funded by the revenue generated from the services we provide the industry. Given our highly discounted rate for lower-budget games, rating mobile games is not a financially attractive proposition; however we believe making ESRB ratings available for those games would serve consumers well. Parents are already familiar with ESRB ratings and find them to be extremely helpful in making informed choices for their families.
To be clear, our desire is to see Apple integrate ESRB ratings as an option in its parental controls and display a game’s rating (if it has one, the ratings are voluntary after all) in the App Store or on iTunes prior to purchase, not to require that every game available via an iPhone carry an ESRB rating (just as not every piece of video content available will carry an MPAA or TV rating).
Apple’s integration of ESRB ratings into its parental controls for iPhone games would afford parents the ability to block those video games that carry an ESRB rating utilizing the same tool they are being offered to block video content that has been rated by the MPAA or carries an official TV rating. It’s about giving parents the same ability to do on the iPhone what they are being offered with other entertainment content and can already do on game consoles and other handheld game devices.
2.) What would it cost?
I asked the ESRB what it costs a developer/publisher to have a typical console game rated? Would the cost to rate an iPhone game be less? Mizrachi said:
Our standard fees for getting a game rated cover the costs of providing that service. However, to make accommodations for lower-budget product like casual and mobile games, several years ago we introduced a highly discounted rate - 80% less - for games that cost under $250,000 to develop. We believe most iPhone games would likely be eligible for the discounted rate.
3.) Isn't this a lot of extra work for ESRB?
Mizrachi was asked whether the ESRB has the capacity to handle an influx of iPhone games for rating. His response:
ESRB has seen increases in rating submissions each year since its founding and has always been able to keep pace. We have rated more than 70 mobile games to date and will undoubtedly rate more in the future as the market grows. Consumers of those mobile games that have been assigned ESRB ratings should have access to rating information, and if parental controls are available, the ESRB rating should ideally be operable within that framework.
4.) If the ESRB plans to do App Store games, what about Xbox 360 Community Games (soon to be known as Indie Games)?
I also asked Mizrachi about the indie games on XBL. Wouldn’t they seem to be a more natural focus for the ESRB before targeting iTunes? Mizrachi said:
Once XNA games graduate to XBLA they are rated by ESRB... ESRB isn't "targeting" iPhone games.
5.) Who would pay for ESRB to rate App Store games?
Not the creators of $0.99 games, for the most part. They are apparently not making significant revenue. Apple has a deep pocket, of course, although they are not the creator of the games for sale on the App Store. Perhaps the larger industry players such as EA, Namco, etc. would foot the bill for their games. They are already accustomed to dealing with the ESRB.
6.) If only some games are rated, why bother?
But then again, if only the commercial game apps from major publishers are rated, how does that stop your kid from downloading Baby Shaker or Hot Dog Down a Hallway? The foundation for the retail employment of ESRB rating is its ubiquity. Major retailers won't carry non-rated games. Thus, parents have a reasonable expectation that their 12-year-old will be turned down if he tries to buy GTA IV. If not all App Store games are rated, such an expectation is not applicable. So, what's the point?
Hopefully we will learn more about the ESRB's plan as we go forward.