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The impetus for (and limited power of) business self-regulation: the example of advergames.

When people complain, government agencies often respond. When regulations are threatened, businesses often offer reassurances that the problems can be handled with a self-regulation code. However, past analyses of the power of self-regulation find that while companies' voluntary adherence to self-defined guidelines may effect some change in the activities of some companies, the inherent limitations of self-regulation in the United States may restrict its ability to actually halt or control the undesired practices of others. The recent response by major food manufacturers and marketers to criticism of online games is all example of this mix.

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Parents and child advocates find threats to children lurking in almost any medium: crazed murderers and bloody severed heads in comic books, a "wardrobe malfunction" during a widely viewed Super Bowl broadcast, television advertising indistinguishable from entertainment, leprechauns collecting candy marshmallows in online games. In the interest of protecting children, they call on government to regulate the practices deemed offensive. The perceived offenders often respond with promises that the problems can be effectively addressed by self-regulation. The proponents of self-regulation argue that free market forces and industry social responsibility are superior to government regulation in addressing a number of issues. Conversely, children's advocates are skeptical about industry's ability to change its practices. In this article, self-regulation of media messages delivered to children is examined, identifying the characteristics that distinguish it from government regulation and addressing the underlying question: Can self-regulation effectively provide consumer protection, and specifically is it sufficient in addressing concerns regarding children and their exposure to food marketing, particularly marketing messages delivered through online games?

Self-regulation has been invoked to address concerns about a variety of perceived dangers that threaten to undermine parental authority or cause negative outcomes in children's socialization, health or education. In the 1950s, the contribution of comic books to juvenile delinquency drew the nation's attention. Up to and throughout the 1990s, violence and sexual depictions on television were at the center of controversy. Repeatedly, advertising targeted to children has been criticized for a variety of reasons, including dental health risks and unfair or deceptive practices, in each of the aforementioned cases, vulnerable businesses that were under attack banded together to proffer voluntary limits to objectionable behavior as an alternative to potentially more restrictive

government regulation, emphasizing their ability and willingness to tie their own hands.

Most recently, and again in response to calls for government intervention, a public concern about childhood obesity and the contribution of advertising to the childhood obesity epidemic has spurred many in the US food industry to adopt self-regulatory guidelines. The Institutes of Medicine has characterized food marketing to children as "out of balance with healthful diets and contribut[ing] to an environment that puts their health at risk" (Institute of Medicine of the National Academies 2006, p.10); organizations such as the Center for Science in the Public Interest called for bans on online food marketing to children as early as 2003 (Teinowitz 2003); parents, pediatricians, psychologists and child advocates have criticized advergames and Internet marketing of foods high in sugar, salt and/or fat (Hellmich 2006).

Proponents of industry self-regulation believe that it can be effective in identifying problems while efficiently and flexibly resolving them. Self-regulation of advertising is claimed to be more successful than government regulation by its encouragement of voluntary adherence to the spirit, rather than simply the letter, of the law. Moreover, supporters believe that self-regulatory codes allow industry to function smoothly, maintain consumer confidence in advertisers, and in general are more effective and cost-efficient than government programs (Miracle and Nevett 1988). indeed, regulators themselves may encourage self-regulation as a positive influence that reduces the need for government involvement (Galloway, Rotfeld, and Richards 2005; Rotfeld 2003; Rotfeld and Stafford 2007).

However, self-regulation may not provide the solution that its advocates claim. Voluntary programs by their very nature lack the ability to compel all industry members to participate, may be difficult to enforce, are unlikely to succeed absent the threat of government regulation, and their goals may not include consumer protection. Rather, "enlightened self-interest" best describes the motivation for many self-regulatory activities (Rotfeld 1992), and absent an actual potential government action, the impetus for self-regulation with any real impact is minimal to nonexistent (e.g., Galloway, Rotfeld, and Richards 2005; Rotfeld 2003). In fact, some critics note that self-regulatory pledges are likely to be self-serving and function to stall, rather than advance, government action and consumer protection (Sharma, Teret, and Brownell 2010).

This article addresses food advertising to children, specifically one frequently used and frequently criticized tactic, the advergame. Following a review of previous self-regulatory programs focused on children and media, the characteristics of food advergames and the nutritional content of the food products in those advergames are provided. The article closes with a discussion of the evidence and implications for public policy regarding the tension between self-regulation and consumer protection.

SELF-REGULATION OF MEDIA TARGETING CHILDREN

Self-regulation usually takes place under the auspices of a trade association, and is codified in general terms in order to accommodate a range of individual company practices (Wotruba 1997). Self-regulatory programs are potentially faster and more efficient than government regulation in effecting change, yet they cannot always be sufficient substitutes as their powers are limited (Rotfeld 1992). They are strictly voluntary, in part in deference to US antitrust laws, and thus rely on each individual firm's willingness to participate (Levin 1967; Rotfeld 1992). Furthermore, self-regulation by its nature is designed to address business goals, and those goals are likely to differ from the consumer protection goals advanced by public advocates and government regulators, thereby benefitting the codes' creators rather than the public (Rotfeld 2001; Sharma, Teret, and Brownell 2010). These characteristics of self-regulatory programs can result in varying and unpredictable adoption by companies. Some companies may fully embrace self-regulation, whereas others may choose to limit self-participation, interpret codes to meet their own purposes, or decline completely.

Self-regulatory codes are frequently created in response to negative publicity. Wotruba (1997) notes that industries often devise codes of conduct in reaction to a threat such as that of potential government regulation, or to counter a negative social trend. He further observes that the "most typical reactive motivation for devising a code of conduct is to counter a negative image" (Wotruba 1997, p. 42). Yet such codes themselves can generate negative publicity and criticism.

Take, for example, the Smart Choices food industry-financed program that used a green check mark logo on the front of packages to identify products meeting industry-determined guidelines for healthier foods. Public health advocates and nutritionists assailed the use of the symbol on products such as the high-sugar Froot Loops cereal or high-fat foods such as mayonnaise. In October 2009, the program was suspended following the announcement of an investigation launched by the State of Connecticut and criticism by the Food and Drug Administration (Skidmore 2009). According to Michael F. Jacobson, executive director of the Center for Science in the Public Interest, "It clearly blew up in their faces...and the ironic thing is, their device for pre-empting government involvement actually seems to have stimulated government involvement" Neuman 2009, p. B1).

One example of self-regulation adopted in response to public outcry is the comic book industry in the middle of the twentieth century. As a popular medium self-defined as targeting children, comic books had long been vulnerable to criticism, but the 1950s ushered in an era of increased pressure, including press coverage, local community regulations and a 1954 US Senate investigation (McAllister 1990). The following section elaborates on this example.

Violence in Comic Books

In 1948, child psychiatrist Fredric Wertham started his attack upon the popular culture medium often (erroneously) perceived as primarily directed toward children, the comic book, for its contribution to juvenile delinquency, providing impetus for the public to rally around the issue. The industry then introduced a self-regulatory code under the umbrella of the Association of Comic Magazine Publishers (Nyberg 1998). This effort by twelve major publishers included an agreement to develop and award a seal of approval to books that met its requirements dealing with sex, crime, torture, language, divorce and ridicule of religious and racial groups (Nyberg 1998; McAllister 1990). Yet illustrating one of the limitations of self-regulation, its voluntary nature, the organization and its code floundered at this time as many large publishers declined to participate (Nyberg 1998). Wertham subsequently released Seduction of the Innocent, a scathing critique of horror comics that blamed juvenile delinquency and youth violence on depictions in the popular comics of the day (Wertham 1953). The issue was not the reliability of Wertham's claims, but that the public believed the claims and called on government to act to stem the perceived damage. Comic book publishers, now facing a realistic fear of government censorship of their business, once again created a self-regulatory structure, with the Comics Magazine Association of America debuting in 1954 and introducing its Comics Code later the same year (Hajdu 2008).

The Code required all comic books to be submitted to the Comics Code Authority prior to publication. Books that passed the review--that is those that met the Code's standards related to storylines, illustration, dialogue, and advertising--would receive the organization's Seal of Approval. To enforce the agreement, local magazine distributors would only carry issues with the seal (Rotfeld 2001). This unique arrangement gave competitors the power to determine whose products would be distributed, but this apparent restraint of trade was ignored as an antitrust violation, with preference given to the professed goal of protecting children (Rotfeld 2001).

Publishers revised the Comics Code twice between 1954 and 1989 as the Authority continued to review comic books prior to publication and continued to award its Seal of Approval (Nyberg 1998). But by 1971, the importance of the seal had declined. An issue of the popular The Amazing Spiderman comic including a story line dealing with the dangers of drugs failed to receive approval because the Code prohibited any mention of drugs, but the book was distributed anyway (Nyberg 1998; Rotfeld 2001), illustrating the lack of an effective enforcement mechanism in the industry's self-regulatory program.

Public attention has since waned, parents are no longer incensed about comic books, and the Comics Code Authority has become irrelevant with the development of new vehicles and new distribution methods. Characteristic of one of the limitations of self-regulation, the disappearance of the threat of government intervention contributed to the code's irrelevance, illustrating its ineffectiveness in generating real change (McAllister 1990; Rotfeld 2001).

As concerns with the influence of comics diminished, attention shifted to the newer medium of television, with critics echoing alarms about the negative effects on youth of violence in media. Similar to the case of the comics, the industry proposed self-regulation to avert potential government intervention.

Violence on Television and the V-Chip Solution

During the mid-twentieth century, several studies attempted to demonstrate a causal link between televised portrayals of violence and violent, aggressive or antisocial behavior in children, including reports from the National Commission on the Cause and Prevention of Violence in 1969 (United States 1969), the US Surgeon General's report in 1972 (United States Senate Committee on Commerce Subcommittee on Communications 1972), a 1984 Attorney General's Task Force report (United States Congress 1984), and a 1985 report from the American Psychological Association Commission on Youth and Violence (APA Commission on Violence and Youth 1993; Cooper 1996; Hoerrner 1999).

The resulting calls for regulation of televised violence met an obstacle in the First Amendment. Content regulation is perceived as a threat to free speech, leading the Federal Communications Commission (FCC) to tell Congress that self-regulation was preferable to government intervention (Kenworthy 2010). The National Association of Broadcasters (NAB) then adopted the "family viewing hour" as part of its self-regulatory Television Code, limiting the times that certain types of content could be shown (Persky 1977). Although the family hour was voluntary--and, in fact, only 416 of the 760 authorized television stations in the United States subscribed to the Television Code at the time (Persky 1977)--it fell out of use by the 1980s, and a subsequent increase in the amount of violence on US television was noted (United States Congress 2000).

In 1992 and 1993, US networks created a warning policy, with a statement transmitted before and during violent broadcasts suggesting parental discretion. Amid concerns that this limited activity was ineffective, legislative proposals continued to be introduced, along with questions about potential antitrust violations if industry competitors agreed to cooperate in their efforts to address violent media content.

A solution came in the Telecommunications Act of 1996, with its mandate that by January 1, 2000, all new television sets would include V-Chip technology linked with a content-based ratings system (U.S. Congress 1996). Broadcasters were to assign ratings to each program, and the V-Chip would allow parents to selectively block material at the television set. This fit the mandate for uncensored content while still providing at least the impression that children's exposure to violent media content could be limited. A coalition of the NAB, the National Cable Television Association and the Motion Picture Association of America developed a ratings system with content indicators for violence, sexual situations, indecent language and suggestive dialogue (United States Congress 2000).

Five years after the V-chip requirement was enacted, its presence in television sets had little, if any, effect on program ratings or viewing habits (Rutenberg 2001). Another five years later, the situation remained stagnant as most parents failed to understand the ratings or how to use the system, even though they owned V-chip equipped televisions (Rideout 2007). Furthermore, the efficacy of the system was questioned in a study finding that children's programs contained significant amounts of violence despite the absence of a violence content rating (Kunkel et al. 2002).

As with the case of the comics industry, self-regulation of televised violence apparently had minimal effect on industry or consumer behavior once the threat of further government intervention faded. Echoing these debates about media violence, advertising to children has been studied and criticized for decades. Once again, industry has offered self-regulation as a solution, and once again questions have been raised about the effectiveness of such plans.

ADVERTISING AND MARKETING TO CHILDREN

Children have long been viewed as a vulnerable group deserving of some extra protection. The Children's Advertising Review Unit (CARU) is an industry-financed self-regulatory agency charged with setting standards to "promote responsible advertising to children," monitoring advertising directed to children and reviewing advertising practices (CARU 2009). Its periodically issued and updated guidelines apply to national advertising directed to children aged 12 and younger, with advertising defined primarily in the sense of traditional, measured media. Recent updates have incorporated guidelines for online advertising, and those, for the most part, mirror requirements in the Children's Online Privacy Protection Act (COPPA) regarding data collection and privacy protection (Federal Trade Commission 1998).

A core CARU principle is that marketers have "special responsibilities when advertising to children" (CARU 2009) because children may not understand either the persuasive intent of the messages or even the fact that the messages are advertising (John 1999). Thus, one CARU guideline explicitly prohibits advertising that "... blurs the distinction between advertising and program/editorial content in ways that could be misleading to children" (CARU 2009, p. 9).

CARU is not the only organization to address the differences between how children and adults may process messages and the potential increased vulnerability of children to persuasion. The use of advertising breaks, also called bumpers or separators, to signal advertising dates to the 1970s when Action for Children's Television sounded an alarm about exposing young children to persuasive messages and called for government policies to protect them (Adler 1980). This advocacy group drew support from a research base that demonstrated that most young children could neither recognize nor defend themselves against the persuasive intent of advertisements. Proposed solutions ranged from limitations on the amount of time commercials could be shown during children's programs to a requirement that advertisements be clearly segregated--by separators--from program content. The NAB developed self-regulatory guidelines for programming directed to children under age 12, and the US FCC adopted them, calling for audio and video devices to separate commercials from program content as well as time limits on advertising (NAB 1979).

The suggestion that separators be used to distinguish children's advertising content from programming comported with an industry call for self-regulation and gained public acceptance, despite the existence of several studies challenging the efficacy of kindred advertising disclaimers aimed at children and youth (Fox et al. 1998; Griffin 1976; Stutts and Hunnicutt 1987), and specifically, questioning the efficacy of program/commercial separators in children's television (Stutts, Vance, and Huddleson 1981).

Industry self-regulation advocates won support for separators despite mounting evidence that expanded beyond simply questioning the efficacy of separators. Palmer and McDowell (1979), for example, found that separators were not only insufficient to get children to distinguish between programs and commercials, but that they "appear to create 'bridges' between programs and commercials--retaining attention without prompting discrimination" (p. 200). Stutts, Vance, and Huddleston (198 l) determined that the presence of separators made no difference in the speed with which children recognized either the commercial message or the return to the program. Later, Mizerski (1995) found that separators are capable of prompting either negative or positive feelings toward the advertised product.

In their report to the American Psychological Association on children's advertising, Kunkel et al. (2004) expressed their frustration at the reliance upon on separators to signal children that an advertising message is on the way. As Moore (2004, p. 163) points out, the "fundamental issues raised about children's capacity to understand and defend themselves against advertising have never been fully resolved." Nonetheless, despite observations of regulators and researchers that children below age 6-8 (Kunkel 2001; Strasburger 2004) consistently demonstrate their incapacity to recognize the persuasive intent of advertising, broadcasters remain required to insert separators between program content and commercials in order that children can differentiate between them (Moore 2004). Separators continue to be offered as an answer for alerting a vulnerable population to the possibility that they will be exploited by advertising the effects of which they may be developmentally incapable of recognizing.

Most recently, food advertising has come under particular scrutiny, with renewed interest accompanying a reported surge in childhood obesity that now affects one in five children in the United States (The Obesity Society 2009). Food marketers, as other marketers in the past, support serf-regulation within an industry-designed and administered framework, while opponents question that approach and call for government intervention.

Food Advertising to Children

Food marketers have been criticized for contributing to the childhood obesity epidemic, with research pointing to a link between food marketing and children's dietary behaviors (Bolton 1983; Borzekowski and Robinson 2001; Boynton-Jarret et al. 2003; Gorn and Goldberg 1982; Gantz et al. 2007; Hastings et al. 2003; Institute of Medicine of the National Academies 2006). Yet questions remain about the strength of the link, as well as the role of other factors that may relate to obesity such as sedentary lifestyle, access to nutritious foods and parental supervision (Hastings et al. 2003; Institute of Medicine of the National Academies 2006). Many advertisers point to research inconsistencies to defend their claims that food advertising is not responsible for the childhood obesity epidemic, or they emphasize their fiduciary responsibility to their stockholders in defense of their marketing activities (Ellison 2005). Once again, industry prefers to self-regulate. However, advocacy groups and some government officials draw attention to the growing number of studies that suggest that food advertising is complicit, at least, in the childhood obesity epidemic, and they call for government intervention (Teinowitz 2005).

The Children's Food and Beverage Advertising Initiative (CFBAI), created in 2006, was introduced by ten of the major US food marketers and the Council of Better Business Bureaus (CBBB) as the debate about the role of advertising in fueling childhood obesity was escalating. According to a report in The New York Times, "[t]he advertising guidelines were released as consumer groups, academics and parents are demanding a crackdown on food marketing aimed at America's increasingly obese children" (Martin 2006).

At the time of the announcement, the ten major food and beverage companies had committed to the initiative's pledge to "... shift the mix of advertising messages to children to encourage healthier dietary choices and lifestyles" (CBBB 2006). This announcement followed substantial publicity and two government workshops that focused on food marketing and the role it plays as a contributing factor helping to shape children's dietary attitudes and behaviors (Institute of Medicine of the National Academies 2006; Seiders and Petty 2007). Since inception, seven more companies have joined the CFBAI; participating companies now account for between 60% and 90% of product sales in their food categories (CBBB 200%, b). The Initiative's core principles define limitations on advertising messages, inclusion of healthy lifestyle messages, reduction in the use of licensed characters, elimination of paid product placements, limits on product use in interactive games, and elimination of certain advertising in elementary schools (CBBB 2009b).

In its October 2009 status report on the CFBAI, the CBBB reported an "excellent level of compliance" and a demonstration of the "commitment of the participants to the program's goal of improving the landscape of children's advertising" (CBBB 2009b). Yet studies of children's television advertising self-regulation have reported inconsistent adherence to both CARU and CFBAI guidelines (Kunkel, McKinley, and Wright 2009).

Historically, advertising to children has been concentrated on television, and researchers thus focused their attention on that medium, but today the entertainment landscape is shifting. Children still watch television. In addition, they are spending more time engaged with a variety of electronic media. Youth aged 8-18 devote about 7.5 hours daily to consumption of various types of media such as television, videos/DVDs, computers and video games (Rideout, Roberts, and Foehr 2010). Even young children, under age 6, spend on average about 1.5 hours daily using screen media (i.e., watching TV, videos or DVDs; playing video games or using a computer), roughly the same amount of time spent playing outside (Rideout and Hamel 2006). Food marketers, recognizing this, use online tools such as the branded online games described below, to reach children.

THE CASE OF FOOD ADVERGAMES

With the popularity of computers and computer games, food marketers have increasingly offered free casual online games on their company-owned Web sites. For example, in a content analysis conducted in 2006, Lee et al. (2009) identified 632 games on Web sites of forty-seven companies that offer food products consumed by or targeted to children. Offering games on food marketers' company-owned Web sites can attract children to visit, stay longer on, and return to the Web sites, increasing exposure to promotional messages about their food products.

One marketing tactic tied to interactive online games involves integrating food brand identifiers--such as brand names, pictures of food or packaging, or spokes-characters--into free online games known as advergames (Lee et al. 2009; Moore and Rideout 2007; Weber, Story, and Harnack 2006). These games, by their nature, blur the line between advertising and entertainment. This fact might challenge, more greatly than other forms of advertising, the ability of children to notice or resist their persuasive intent (Cole and Quilliam 2008; Moore and Rideout 2007).

For example, in the Lucky Charms Cereal game Keep Me Mini, a child takes the role of the Lucky Charms brand spokes-character, Lucky the Leprechaun. To win the game and move to a higher level of skill, the leprechaun is required to collect as many "charms" as possible; the charms resemble the marshmallow candy pieces in the cereal. Thus, the child game player is interacting with the branded product, rather than passively observing it as in a television advertisement, and is rewarded for amassing as great a quantity of the brand's products as possible in a limited time. Tying game play even more closely to the brand, children are encouraged to enter codes found on the Lucky Charms cereal box to earn a "bonus burst of energy."

Playing a food advergame may influence children's food preferences and choices, making the promotion of foods of low nutritional value using advergames particularly disturbing. Mallinckrodt and Mizerski (2007) found that older children (seven- and eight-year-olds) who played the food advergame, Froot Loops Toss, preferred Froot Loops to other cereals and to other food categories, compared to those who did not play the advergame, although younger children (five- and six-year-olds) both in the advergame playing condition and in the control condition preferred Froot Loops over other food options. In addition, in an experiment with African American third and fourth graders, Pempek and Calvert (2009) found that children who played the advergame promoting healthier food options (e.g., bananas and orange juice) were more likely to choose healthier food options after game play than those who played the advergame promoting less healthy food options (e.g., soda and potato chips); similarly, those who played the advergame promoting less healthy food options were more likely to select less healthy food options than those who played the advergame promoting healthier food options.

Several content analyses conducted between 2004 and 2006 found that advergames were used extensively to promote food products to children (Lee et al. 2009; Moore and Rideout 2007; Weber, Story, and Harnack 2006). In 2005, Moore and Rideout (2007) analyzed seventy-seven Web sites of food brands that have content for children and identified 546 advergames; in another content analysis previously mentioned, Lee et al. (2009) found that 87.6% of the interactive games sampled for their study were advergames. In addition, the majority of the children's food advergames integrate brand identifiers as active game components, allowing children to "play with" virtual food products in games (Lee et al. 2009). Moreover, food advergames, such as television food advertisements directed to children, have been found to promote foods of low nutritional value (Lee et al. 2009; Moore and Rideout 2007). Once again, self-regulation became the solution of choice for the industry.

Self-Regulation and Food Advergames

Despite vocal public concern, calls for enhanced regulation, and voluntary industry advertising self-regulation, food marketing messages in advergames continue to target children. Whether children play the games or change behavior based on this type of message is not the relevant concern. Rather, the issue is that the games are perceived as problematic, so regardless of evidence, government agencies might respond in a restrictive fashion to quiet the critics.

As stated above, most CARU guidelines apply to traditional, measured media. There is, however, one area where CARU guidelines unquestionably address online marketing and advergames on company Web sites. One CARU guideline states "On Web sites directed to children, if an advertiser integrates an advertisement into the content of a game or activity, then the advertiser should make clear in a manner that will be easily understood by the intended audience, that it is an advertisement" (CARU 2009, p.9). The guideline does not, however, provide a precise definition of integrating "an advertisement into the content of a game or activity," nor does it offer suggestions regarding the format, size or content of the recommended notice.

As noted above, there is little extant research regarding the effectiveness of advertising breaks or separator devices, particularly in the online environment, as most academic studies of such devices predate the emergence of the Internet as a significant entertainment medium for children. In a study of online food marketing to children (Moore and Rideout 2007), only 18% of the marketers' Web sites were found to include ad break reminders, but details about where these announcements appeared--that is, whether they were in proximity to an advergame or to other online content--were not provided. The presence of such notices may mitigate the persuasive effects of advergames (An and Stern 201 l), but little is known about how to develop and display a relevant, salient message that can trigger children's persuasion knowledge. Indeed, An and Stern report that while ad breaks resulted in reduced recall and brand preference, they did little to increase children's awareness of the site's sponsor, nor did they increase children's understanding of the underlying motive of the advergame. Moore and Rideout (2007) also noted the need for more research into online ad breaks, given the dearth of information regarding either their effectiveness or, if effective, of the appropriate format, size, and placement of such notices.

Despite the lack of empirical evidence regarding the effectiveness of advertising breaks or separator devices as tools for communicating with children, and despite the vagueness of the CARU guidelines regarding such notices, here again the issue is not whether separators are effective, but rather whether the public thinks they are effective. The self-regulatory guideline calling for separators acknowledges the public concerns and the companies implementing these limits are responding to those concerns and to possible government intervention. The extent to which companies include separators could be indicative of their commitment to the "responsible children's advertising" envisioned by CARU.

Other CARU Core Principles and Guidelines, although not explicitly referencing online promotions including advergames, are germane in terms of their intent. For example, Core Principle #7 states "Advertisers are encouraged to capitalize on the potential of advertising to serve an educational role and influence positive personal qualities and behaviors in children, e.g., ... engaging in physical activity" (CARU 2009, p. 5). One way that marketers can promote these behaviors online is via inclusion of healthy lifestyle messages presented before, during and/or after game play.

Focusing on food marketing to children, CFBAI companies make individual pledges to devote at least half of their television, radio, print and Internet advertising directed to children under age 12 to products that they identify as "better for you," that is, "... products that have fewer calories and are lower in fats, sodium and sugars, and/or are nutrient dense" (CBBB 2009b, p. i), or to include healthy lifestyle messages in their advertising. Most companies' pledges exceed the 50% standard originally established, committing to either eliminate all advertising to children (Cadbury, Coca Cola, Hershey's and Mars) or to including "better for you" products or healthy lifestyle messages in 100% of their advertising; in late 2009, the standard was raised to 100% for all participants (CBBB 2009b).

In addition to the pledges regarding advertising in traditional measured media, the CFBAI commitments include limits on use of products in interactive games: "Participants will commit that, in any interactive game primarily directed to children under 12 where the company's food or beverage products are incorporated into the game, the interactive game must incorporate or be accompanied by products representing healthy dietary choices ... or healthy lifestyle messaging ..." (CBBB 2009b, p. 57). The Initiative company commitments allow for either "better for you" products or healthy lifestyle messages, but do not mandate that both appear in advergames.

Finally, a key tenet of the CFBAI program is that each company determines what nutritional criteria it will use to identify "better for you" products, with the only stipulation that each company's standards be "consistent with established scientific and/or government standards" (CBBB 2009b, p. 57). Some examples are provided, but companies are free to choose their own criteria. The result is a wide range of standards rather than a single benchmark. For example, some companies include products that represent a 25% or more reduction in calories, sugar, fat or sodium from some reference food, rather than requiring that all foods meet specific nutrition criteria. Others determine which products qualify based on proprietary programs (e.g., Kraft Foods' Sensible Solution) or the industry-sponsored Smart Choices program that was suspended following complaints about its lack of rigor.

Given the expressed intent of the pledges, it is reasonable to expect CFBAI-participating companies' advergames to be more likely to include the restrictions noted above than similar games offered by nonparticipating companies. In the following section, a content analytic study addressing these expectations is described. The study was conducted to investigate how the self-regulating companies have addressed advergames, and to compare the participants' advergame offerings to those of nonparticipants.

THE EVIDENCE

Content analysis has been used in previous studies for assessing advertising practices including implementation and adherence to regulatory or self-regulatory guidelines (Rotfeld and Taylor 2009). This study used this technique to examine major food marketers' adherence to self-regulatory guidelines regarding food advergames.

A sample of interactive games that might be accessed and played by children was obtained following the sampling steps used by Lee et al. (2009), during the first half of 2009. (1) Specifically, the food companies and brands that appear to be promoting products consumed by or targeted to children were first identified by having a research assistant visit the Web sites of 168 top-selling food companies: the top twenty-five food companies in each of six major food categories (i.e., baked products, dairy and beverage, fruits and vegetables, meals and entrees, meat and poultry and snacks/appetizers/side dishes) (Refrigerated and Frozen Foods 2008); the top ten fast food companies (Brandweek 2008); and the top eight family-restaurant companies (Nation's Restaurant News 2008). The top-selling food companies were selected because their products are likely to be consumed by a large number of consumers, including children. To examine as many brands that might be targeted to or consumed by children as possible, brands were excluded only if they were clearly not child oriented (e.g., the site displayed an age requirement). This list was augmented by visits to the Web sites of the companies and brands that were included in Lee et al.'s (2009, pp. 149-151) database, as well as the brands included by CFBAI participating companies on their lists of "Food and Beverage Products that Meet Participants' Approved Nutrition Standards" (CBBB 2009a).

Second, to identify the interactive games appearing on the Web sites of the food marketers promoting products consumed by or targeted to children, two research assistants visited the Web sites identified above and found a total of 420 games offered by thirty-one companies for eighty-seven brands. Some games were easily identifiable as targeted to children based on the images that were incorporated into the games, or based on specific language addressing children. Other games might appeal to different ages. This study excluded games that clearly targeted adults (e.g., by including a requirement to enter a birth date), but otherwise included games that might be seen and played by children. The number of games available on each food company's Web site ranged from one to eighty-six (Mean = 13.55, SD = 21.78). Finally, to obtain a manageable sample, 51% (n = 214) of the games were selected for content analysis using a random number generator (www.randomizer.org). Among the 214 games, forty-eight were removed from the subsequent analyses because they were not available later for intercoder disagreement resolution. Thus 166 games were included in the subsequent analysis. The final sample did not include games from all thirty-one companies due either to random selection or to lack of availability of the game for intercoder disagreement resolution.

Stage I: Content Analysis of Games

The first stage involved a content analysis of interactive games that children might locate and play on food companies' Web sites, and the unit of analysis for stage I was a game. The type of company was first coded, either a CFBAI participant or nonparticipant as of May 2009. Coders then identified whether the game included any type of brand identifiers, such as brand names, pictures of food or packaging or spokes-characters, thus qualifying as an advergame. Games that did not include such identifiers were excluded from further analysis. Next, the presence (or absence) of an advertising break or notice--for example, "Hi kids, when you see 'Ad Break' it means you are viewing a commercial message designed to sell you something"--was coded. In addition, the presence (or absence) of healthy lifestyle information was coded. Healthy lifestyle information includes healthy diet/nutritional suggestions (e.g., "Pecans and Cashews contain zinc, which helps support a healthy immune system.") or physical activity suggestions (e.g., "Getting online is great--but so is getting outside to play! See you in 15 minutes with some ideas about how to get you to move on."). Finally, if the company was a CFBAI participant and if the game included identifiable food products, the inclusion of their "better for you" (2) products in the advergame was further coded into three categories: a game without "better for you" products, a game with "better for you" products only and a game with both "better for you" products and non-"better for you" products.

After spending 13 hours each of training and practice coding, coders spent, on average, 80 hours each to code all the games. Intercoder reliability was computed using Krippendorff's alpha, with a range from .81 to .96, exceeding the acceptable level suggested in the literature (Rust and Cooil 1993). All disagreements were resolved through revisiting the advergames and discussion between the two coders.

Prevalence of Advergames on Food Marketers' Web Sites

Among 166 interactive games analyzed for this study, 88% included some type of brand identifiers, thereby meeting the definition of an advergame. Among all the advergames analyzed, CFBAI participating companies offered 69.2%. (3) This study did not locate any advergames for either Coca Cola or Hershey, indicating their full adherence to their pledges. However, this study located four games offered by Mars and one by Cadbury. The Cadbury game did not meet the definition of an advergame targeting children. One of the games offered by Mars was no longer available when coding began. At the time of writing, two of the three Mars games were age restricted.

Advertising Breaks in Food Advergames

As mentioned earlier, the self-regulatory codes include requirements for explicitly identifying advergames as advertising. There were significant differences between advergames offered by companies participating in the CFBAI and those offered by nonparticipants in terms of the inclusion of advertising breaks, [chi square] (1) = 8.35, p < .01 (Table 1). Specifically, among the advergames offered by CFBAI participants, 61.4% included a separator, whereas only 35.6% of the advergames presented by nonparticipants had such notices.

Healthy Lifestyle Information and "Better for You" Products in Food Advergames

The CARU Principles also encourage advertisers to educate children to engage in positive behaviors such as physical activity. There was no difference between CFBAI company advergames and advergames presented by nonparticipating companies in terms of the inclusion of healthy lifestyle information, [chi square] 2(1)= 2.62, p = .11 (Table 1). Among the advergames offered by CFBAI participants, 32.7% included healthy lifestyle messages, whereas 46.7% of the advergames presented by nonparticipants included healthy lifestyle messages.

Moreover, the CFBAI guidelines emphasize providing healthy lifestyle information and/or promoting only self-defined "better for you" products that meet their individual nutritional standards. Among the CFBAI company advergames into which their companies' identifiable food and beverage products were incorporated, 28.6% included "better for you" products only; 7.1% included healthy lifestyle information only; 15.7% included both "better for you" products and healthy lifestyle information and 48.6% included neither of these.

Stage II: Nutritional Content of Advertised Foods

To examine the nutritional content of foods in advergames, all the food products in each game were identified, revealing a total of 119 unique food products. A research assistant collected five types of nutritional information--serving size, total calories, calories from fat, sodium and sugar--by reviewing the nutritional facts labels on company Web sites. Following the procedure adopted by Harris, Schwartz, and Brownell (2010), a food product was classified as unhealthy when the food product met one or more of the following criteria based on the Nutrition Standards for Foods in Schools guidelines (4) (Institute of Medicine of the National Academies 2007): (1) more than 200 calories per serving, (2) more than 35% of its calories per serving are from fat, (3) more than 35% of its calories per serving are from sugar or (4) it contains more than 200 mg of sodium.

This study found that there was a significant difference between CFBAI company advergames and those offered by non-CFBAI participants in terms of the inclusion of food and beverage products that meet outside nutritionists' recommendations, [chi square] (2) = 7.88, p < .05 (Table 1). Among the CFBAI company advergames into which their companies' food and beverage products were incorporated, 12.9% included healthy food products only; 78.6% included unhealthy food products only and 8.5% included both healthy and unhealthy food products. However, among the non-CFBAI company advergames into which their companies' food and beverage products were incorporated, 36.7% included healthy food products; 53.3% included unhealthy products and 10% included both healthy and unhealthy food products.

DISCUSSION AND CONCLUSION

The primary issue addressed in this article is the effectiveness of self-regulation in changing business behavior, particularly as it relates to media interactions with children. A review of previous programs adopted by businesses to avert government regulation demonstrates that voluntary guidelines can be effective at quieting public outcries, appeasing parents and averting further government action. Yet, as seen over the past five decades, there is limited evidence that such programs truly change business practices and address the broader issues that generated the concerns in the first place.

The Comics Code Authority was perceived as an acceptable means of addressing public criticisms of the medium, even as it appeared to violate antitrust laws. Companies still point to its existence as evidence of their commitment to consumer protection, despite the Code's irrelevance today (McAllister 1990; Rotfeld 2001). The voluntary industry rating system that accompanies the V-Chip requirement in the Telecommunications Act of 1996 has dampened further interest in attempting to regulate television content, despite the fact that few parents seem to utilize the technology. Commercial separators are commonly accepted vehicles for distinguishing advertising from content in children's programming, reinforcing the idea that they are effective in protecting children from persuasive messages despite the absence of research to support that contention. Most recently, food-marketing self-regulation is touted as the industry's solution to the childhood obesity crisis.

In this study, one food advertising tactic was examined, the online interactive game. The predominant industry response to criticism about food marketing to children has been the creation of the CFBAI and its inclusion of guidelines addressing advergames. Applying standard criteria, rather than the customized individual company criteria allowed by the CFBAI, this study found that only about half of the advergames offered by those companies incorporating food and beverage products included their "better for you" products and/or healthy lifestyle messages. In addition, CFBAI companies were no more likely than noninitiative companies to include healthy lifestyle messages.

Under CFBAI guiding principles, each company is free to determine its own nutritional guidelines with the caveat that they are to be grounded in science or government standards. To analyze the nutritional content of products incorporated into advergames across all companies, this study adopted the Nutrition Standards for Foods in Schools (Institute of Medicine of the National Academies 2007) and used that classification of healthy and unhealthy foods to assess whether advergames that might be seen and played by children are being used to promote healthy foods, or are instead being used as vehicles to market unhealthy foods. The evidence shows that, although it may seem contradictory, at least some of the companies who "took the pledge"--the CFBAI initiative companies--appear to be less responsive to public concerns about the types of products promoted in advergames that might be seen and played by children than are the companies that have not signed on to the CFBAI voluntary guidelines. Specifically, and perhaps most disturbing, CFBAI company-sponsored advergames were more likely to include greater proportions of unhealthy foods (vs. healthy foods) than advergames offered by other companies. Nonparticipating companies, in fact, incorporated healthy foods in their advergames at three times the rate of the self-regulating CFBAI participants.

The results of the advergame analysis are consistent with reports from other domains of food marketing, such as licensed character promotions on food packages (Harris, Schwartz, and Brownell 2010) and television advertising on children's programs (Batada and Wootan 2009): There still seems to be a chasm between the industry's expressed intention and its related behavior. The limitations of self-regulation of children's media messages, as identified in the past with comics, television and advertising breaks, prevail in the food marketing environment as well, and online games are no exception. Self-regulation is by definition voluntary; companies are not legally compelled to participate and not all do. The participants design guidelines that appear to meet public needs but in reality may be more accurately described as attempts to deflect attention and quiet the industry's critics.

In the domain of food advergames, although some companies fully observe both the letter and spirit of the self-regulatory programs and their individual pledges, self-regulating marketing to children has not resulted in the elimination of promotion of unhealthy foods. Government regulations mandating specific nutritional standards and acceptable media for marketing food to children could address the inconsistencies identified in this research. As with other examples of self-regulation, the threat of government regulation might encourage broader modifications to the food marketing landscape such as participation in the CFBAI by companies not currently committed and more rigid and consistent standards for all food marketing directed to children; that threat is at a minimum a prerequisite for self-regulation. Yet the advergame example once again demonstrates the inadequacy of self-regulation for effecting real change that addresses the consumer interest.

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(1.) Although the CFBAI status reports issued in 2008 and 2009 included lists of Web sites and some examples of interactive games (CBBB 2008, 2009a, b), this study's search for interactive games in general and advergames in particular was inclusive of nonpledge companies that do not publish such lists. Thus, this study's evaluation was not based on the CFBAI company self-identification of their child-directed Web sites and advergames. Rather, an extensive search was conducted to locate as many games as possible, applying the same selection criteria regardless of company CFBAI participation.

(2.) When coders coded an inclusion of "'better for you" products, they consulted the "better for you" products lists, self-defined and published by the CFBA1 companies. The "'better for you" designation is part of the CFBAI company pledge, identifying products that meet each company's nutrition standards, and thus could be coded only for those companies (CBBB 2009a, b).

(3.) One reviewer suggested that stratified random sumpling would have been more appropriate than simple random sampling to examine to what extent advergames are used by CFBA1 companies vs. non-CFBAI companies, due to the possibility that games offered by CFBAI (vs. non-CFBAI) companies might have been over- (or under) represented in this study's randomly selected sample. Although we agree with this comment as a direction fur future research, this is not a problem in the context of the explanations and context of the current study. In this study's initial sample (n = 420), 64.3% of the interactive games were offered by the CFBAI participants. Similarly, in this study's randomly selected sample (n = 214), 63.1% of the games were offered by the CFBAI participants. Therefore, we feel confident that simple random sampling used in the current study resulted in the randomly selected sample that reflects the composition of the initial sample.

(4.) A comparison of these standards with the guidelines used by the CFBAI participating companies reveals that, with respect to calories, two companies use a more generous standard. one has the same limit, and others are stricter. With respect to fat, four companies did not specify a standard, four have stricter guidelines than the 35% limit, and two use the same limit. For sodium, eight companies have more generous standards, two have stricter standards, and one did not specify a sodium limit. The allowable sugar limit is higher than the standard used in this study for six companies and stricter for five. The Nutrition Standards tier Foods in Schools guidelines are more stringent than some of the CFBAI participating companies, but using these guidelines allowed us to make nutrition comparisons across all food products, rather than taking the narrow focus of determining whether each company complied with its own definition of nutrition, thereby delimiting its own pledge.

Elizabeth Taylor Quilliam (quilliana@msu.edu) is an Assistant Professor and Richard T. Cole (rcolel@msu.edu) is a Professor, both at Michigan State University. Mira Lee (miralee.umn@gmail. corn) is an Associate Professor at Chung-Ang University, South Korea. Mikyoung Kim (kimi3@msu.edu) is a Senior Researcher at Ewha Women's University, South Korea. The authors gratefully thank Jef I. Richards for his guidance and advice on this article.
TABLE 1
CFBAI Participants' Games Versus Nortparticipattts' Games

                                         CFBAI         Nonparticipants'
                                      Participants'         Games
                                     Games (n = 101)       (n = 45)

Advertising break
  No                                   38.6% (39)         64.4% (29)
  Yes                                  61.4% (62)         35.6% (16)
[chi square] (1) = 8.35, p < .01
Healthy lifestyle information
  No                                   67.3% (68)         53.3% (24)
  Yes                                  32.7% (33)         46.7% (21)
[chi square] (1) = 2.62, p = .11
Nutritional content'
  Unhealthy foods only                 78.6% (55)         53.3% (16)
  Healthy foods only                   12.9% (9)          36.7% (11)
  Both unhealthy and healthy foods      8.5% (6)            10% (3)
[chi square] (2) = 7.88, p < .05

(a) This analysis is based on advergames into which companies' food and
beverage products are incorporated (CFBAI participants' games, n = 70;
nonparticipants' games, n = 30).
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Date:Jun 22, 2011
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