Ad description
A TV ad for Lucky Cow Bingo, seen on 14 December 2023, featured a cow stood on its hind legs dancing to music against a bright purple background. The voiceover stated, “Someone’s happy. Get that lucky cow feeling with luckycowbingo.com. The home of brilliant bingo, super slots and beautiful bonuses like this…Get that lucky cow feeling with up to 500 free spins at luckycowbingo.com.” On-screen text stated, “luckycowbingo.com/bingo”.
Issue
The complainant challenged whether the content of the ad was likely to be of strong appeal to those under 18 years of age, and therefore breached the Code.
Response
Jumpman Gaming Ltd t/a Jumpman Gaming said the dancing cow character was a visual representation of the “Lucky Cow” bingo brand and that the dancing was intended to portray the “lucky” element of the “Lucky Cow” brand name. The cow was not dancing to music that would have been of strong appeal to children and it did not speak or address the viewer. They said they had ensured the cow was not cuddly or cute and although animated, it was not cartoon-like and none of the cow’s features were exaggerated. There was no similarity between the cow and any animations or toys that might be known to children or young people.
Clearcast said the cow animation was a photo-realistic style. They believed that the cow was not cute or cartoon-like and did not resemble an animation style that would be of strong appeal to under-18s. They considered the dance movements of the cow were reminiscent of early digital computer Graphics Interchange Format (GIFs) geared towards an adult audience who would remember and appreciate that nostalgic approach.
They said the music in the ad was generic. It had no lyrics or jingles that would appeal to under-18s and bore no resemblance to pop tracks, cartoon themes, nursery rhymes or well-known songs. They considered that the combination of the dancing cow and the generic track, whilst fun, was designed to represent the “Lucky Cow” branding and would only be of appeal to the advertiser’s target, adult, audience.
Assessment
Not upheld
The BCAP Code required that advertisements for gambling must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. The CAP guidance, “Gambling and lotteries advertising: protecting under-18s”, stated that advertiser-created characters that are colourful or have exaggerated features are more likely to be of strong appeal to under-18s, especially those resonate of children’s characters; for instance, ‘cuddly’ or ‘cute’ animals.
The ASA acknowledged that the dancing cow featured in the ad was unusual and whimsical. However, we considered that, while it was apparent the cow was not a real animal, it was life-like in its depiction, did not have exaggerated features and had not been digitally altered to make it cute or cartoon-like. Further to that, the cow was not overly colourful, and did not resemble a soft toy or a character from children’s stories.
The music featured in the ad had a cheerful tone, but we considered that it was generic in style with no lyrics and was not associated with known songs that were likely to be of appeal to under-18s.
While the bright colours in the ad and the dancing cow could appeal to some children or young persons, given the overall presentation of the character, on balance we concluded that the ad was not likely to have strong appeal to under-18s.
Action
No further action necessary.
