Background
This Ruling forms part of a wider piece of work on paid-for gambling-like ads, identified for investigation following intelligence gathered by the ASA. See also related rulings published on 25 September 2024.
Ad description
Two paid-for TikTok ads for “Ignite Classic Slots”, a social casino game app, seen in March 2024:
a. The first ad featured an individual in front of a slot machine holding a large amount of money, as they said, “I have over 200 grand in my bank account because I stopped going to casinos and started playing this mobile slots game where I haven’t spent any money; however, I can still win super big. It’s called Ignite Classic Slots […] I play for tons of reasons. First it’s free, and it’s free to play, second it has super, high odds of winning jackpots, plus its designed by real casino experts […] And if you want to download from this video right now you’ll get 12 million coins in a welcome bonus so tap here and play for free today.”
On-screen gameplay imagery accompanied the on-screen text and included slot machine and spinning wheels, as well as text that stated “BIG WINS” and “SUPER WIN”.
b. The second ad opened with a slot machine being played by an off-screen individual who said, “Lets go, winner […] be a miracle […] ” before the shot cut to a different individual in front of another slot machine who said, “Casinos are taking a gamble that you will take a gamble and lose all your money. Why not save that money and spend it on a much better thing? Download Ignite Classic Slots. Download from this video and you get 3 million free coins just for signing up.” At the same time a mobile phone notification appeared at the top and displayed text that stated “You just received [coin emoji] 3000000 coins”.
The individual then continued, “When you play it’s a 100% hit rate […] even at level 1 you can play over 300 slot machines for free more than all machines in this casino combined […] it’s free to play, it’s free to download, and you get that big bonus right now.” At the same time, a carousel of slot machines was shown at the top of the video.
Issue
The ASA challenged whether the ads misleadingly implied the social casino game was a gambling product in which real-world money or tangible prizes could be won and withdrawn.
Response
Mobee Co. Ltd did not respond to the ASA’s enquiries.
TikTok said restrictions applied to the advertising of social casino games on their platform and that included the prohibition of content implying that users could earn real-world money or where direct comparisons to gambling were made. They said the ads had breached TikTok ad policies, and as such, they had removed the ads from their platform.
Assessment
Upheld
The ASA was concerned by Mobee Co. Ltd’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in the future.
The ASA understood that social casino apps emulated slot machines or other casino-based games. However, we understood consumers were unable to win or withdraw any real-world money or tangible prizes from such apps, and therefore, they were not gambling products. We further understood that, whilst real-world money was not required to play, there were in-game purchase options available which enabled consumers to buy in-game currency or additional gameplay features.
Ad (a) featured an individual who said that, as a result of playing the Ignite Classic Slots app instead of gambling at casinos, they had over £200,000 in their bank account”. We noted that the scene was realistic; the individual was seen holding a substantial amount of real-world money and they appeared to be in a casino, sitting directly in front of a slot machine. Because of that, we considered consumers would interpret that to mean the individual featured had won a significant amount of real-world money via the app, despite not having spent any real money. Furthermore, in the context of the imagery of an individual holding a large amount of money, we considered that “win a lot” would be interpreted as winning a lot of real money.
Later on in the ad, gameplay footage from Ignite Classic Slots appeared on screen, as the individual continued to speak. The featured gameplay emulated casino-based gambling such as slot machines and a roulette wheel, and we considered that consumers, seeing the gameplay footage alongside the individual situated in a casino and adjacent to a slot machine, would understand that Ignite Classic Slots was similar to traditional casino-based gambling and that it would be possible to win real-world money or other tangible prizes. We considered that impression was further reinforced by the description that the game was “designed by real casino experts” and that consumers would infer the app offered a similar casino experience. In addition, the ad contained numerous references to winning and odds, for example, “super-high odds” and “jackpot”. We considered such terminology was commonly associated with gambling and the chances of winning real-world money or prizes. Their inclusion in the ad contributed to the impression that consumers could gamble, win and withdraw real-world money through the Ignite Classic Slots app.
Ad (b) featured an individual playing a slot machine in a casino who quickly becomes frustrated with losing their bet, juxtaposed with a different individual, also seen in a casino, who discussed the risk of losing one’s stake at a casino. Instead, the individual suggested that consumers should save the money they would have otherwise spent in a casino and use it to download the Ignite Classic Slots app. Because the ad contrasted losing within a casino environment and implied that it would be more beneficial to spend that money on the app, we considered consumers would interpret that to mean the experience of playing the game was analogous to gambling in a traditional casino, but unlike physical casinos, an individual’s chances of winning real-world money were higher when playing Ignite Classic Slots.
That impression was reinforced by the statement that the app contained over 300 slot machines, which the second individual in the ad stated was, “more than all machines in this casino combined”. We considered that would be interpreted by consumers to mean the app provided an enhanced experience to playing traditional casino slot machines and, within the context of those comments, that individuals were likely to lose money at a casino and the probability of winning on the app was greater. We considered the slot gameplay footage, along with repeated references to “coins”, which were commonly associated with slot machines, and the phrases “big bonus” and “100% hit rate” further strengthened the impression that the app offered an enhanced experience of playing slot machines in a casino where real money would be won.
However, we understood that Ignite Classic Slots was a social casino game, and users could neither win nor cash-out real-world money. We acknowledged that the function of the app was to emulate the experience of playing a slot machine or other casino-based games. However, we considered that consumers would interpret the ads to mean that, because the app was comparable to a real-life casino experience, consumers would be able to gamble as they would in a casino and win large amounts of real-world money.
Because we considered the claims and imagery featured in the ads gave the impression that the apps were gambling products in which real-world money or tangible prizes could be won and withdrawn, we concluded that the ads were misleading and had breached the Code.
The ad breached CAP Code (Edition 12) rules 3.1 and 3.3 (Misleading Advertising).
Action
The ad must not appear again in its current form. We told Mobee Co Ltd to ensure they did not imply consumers could win real-world money or tangible prizes. We referred the matter to CAP’s Compliance team.
