Marketing Media Violence: An Interview with FTC Attorney, Linda Stock

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by Jeff Burman

On September 11, the Federal Trade Commission issued a provocative, finely nuanced report entitled “Marketing Violent Entertainment to Children: A Review of Self-Regulation and Industry Practices in the Motion Picture, Music Recording & Electronic Game Industries.”

The report concluded that despite self-regulatory systems already in place, members of all three industries routinely target the advertising and marketing of violent entertainment directly to children. The Commission believes that these efforts undermine each industry’s parental advisories and frustrate parents’ attempts to protect their children from inappropriate material.

It also reported that while most studies show a high correlation between exposure to media violence and aggressive behavior, there is no conclusive causal link to such behavior, especially outside the testing environment. Instead, the studies point to a complex array of behavioral and economic factors that contribute to the causes of violent behavior.

In response to its findings, the Commission believes that all three industries should take additional action to enhance their self-regulatory efforts. Although the report makes no legislative recommendations, the Commission believes that continuous public oversight is essential and that Congress should continue to monitor the progress of self-regulation in this area. For more on the report, see www.ftc.gov/opa/2000/09/youthviol.htm

Linda Stock is one of a staff of fourteen that researched and wrote the report. To gain insight into the possible changes that might occur in the ratings process, CineMontage interviewed her in late September.

“Children under the age of seven or eight generally cannot distinguish that violence in the media isn’t real. They think it’s actually happening.” – Linda Stock

Jeff Burman: Linda, how were you chosen for this project?

Linda Stock: Luck, I guess! All the other people on the team are in Washington, and it was felt that a presence on the West Coast would be helpful. Let me add that my comments to you about the report are my own, and don’t necessarily reflect the opinion of the FTC or the commissioners.

JF: Did they give you a specific area to research?

LS: We were to confine our studies to the marketing of violent entertainment to children. We weren’t to consider the actual content of movies, music lyrics or electronic games. All we were supposed to consider was whether or not the entertainment industries targeted children for entertainment that they themselves had rated as appropriate for more mature audiences.

I’ll tell you exactly what I did. I participated in interviews at the movie studios. I wrote the section on third party views and suggestions for improving the ratings systems – Appendix G. And I wrote the history of the movie rating system. I also reviewed some of what the public thinks of the three industries’ rating systems.

JF: Who were some of the third party advocacy groups you spoke to?

LS: The commission sought comments from professional health organizations, academics, parents and consumer advocacy groups. The American Academy of Pediatrics, the American Psychological Association, the Center for Media Education, the Lion and Lamb Project, Mediascope, the Parents’ Music Resource Center; I hate to just name a few, because there were so many.

“The three entertainment industries that we looked at know that not only will Congress be looking at them, but public opinion strongly wants this marketing of violence to children to stop.” – Linda Stock

JF: Were their conclusions pretty consistent?

LS: We heard some of the same things repeatedly. They wanted more descriptors included in the ratings. By that I mean, for example, a “V” for violence, a “D” for dialogue or an “S” for sexuality. The electronic game industry already includes descriptors in their ratings. The MPAA makes the meaning of ratings categories available on the Internet, but they don’t have descriptors in movie ads at this time.

That likely will change. The music industry doesn’t use descriptors at all. They don’t even use age ratings. They just label certain recordings with “explicit content” labels.

[Another suggestion, from Appendix G, is for a new “A” rating for adult material that’s not pornographic. Such a rating could either replace the infrequently used NC-17 rating, or it could be used between the “R” and “NC-17” ratings. There is a further recommendation, which calls for MPAA members to be child development professionals, educators and media professionals rather than just parents, as it’s currently constituted. Some advocacy groups also raised the possibility that those who review films for the board may suffer from desensitization–they see some 600 to 700 films a year. There have also been calls for a single, unified rating system for all branches of the entertainment industry. – Jeff Burman]

JF: Is there movement toward providing more descriptors?

LS: The Directors’ Guild of America is advocating a rating system that would include the reasons for a rating. When such a prestigious group calls for a system like that, I’m confident that it’s going to happen. On September 26, the MPAA came out with a statement that the film studios are seeking ways to include the reasons for their ratings in print ads and on their web sites.

JF: When you spoke to the studios, what did you find out?

LS: The studios were cooperative, and we greatly appreciated their openness and sincerity. But, we found out that it’s extremely clear that all three of the entertainment industries that we examined are targeting children for violent entertainment.

“We were to confine our studies to the marketing of violent entertainment to children. We weren’t to consider the actual content of movies, music lyrics or electronic games.” – Linda Stock

JF: They’re not prohibited from marketing to anyone they choose. Is that correct?

LS: Yes. There are Supreme Court decisions limiting the marketing and exhibition of obscenity. But, the Court hasn’t extended its rulings to violence. There are no laws currently on the books that say that the movie industry or the electronic game industry or the music industry cannot target children for violent entertainment.

JF: If the industry felt no legal reason not to market to children before, what would make them change?

LS: The electronic game industry has already said they would not target children for violent materials. In late August, the music industry said they are going to encourage their members to not market violent materials to children. In the Sept. 26th statement, the MPAA pledged that the studios would not specifically target children in the advertising of R-rated films.

JF: This is all intended to be done voluntarily.

LS: The three entertainment industries that we looked at know that not only will Congress be looking at them, but public opinion strongly wants this marketing of violence to children to stop. There’s legislation pending, the Media Violence Labeling Act of 2000, that was introduced in the U.S. Senate in May. It calls for “the establishment, use and enforcement of a consistent and comprehensive system in plain English for labeling violent content in audio and visual media products and services,” including labeling in its advertising. If the entertainment industry doesn’t voluntarily establish a labeling system, Congress would have the FTC issue regulations to do so. But the Federal Trade Commission is definitely calling for self-regulation rather than having Congress pass any legislation. The FTC has always been a strong proponent of self-regulation.

“We heard some of the same things repeatedly. They wanted more descriptors included in the ratings. By that I mean, for example, a ‘V’ for violence, a ‘D’ for dialogue or an ‘S’ for sexuality.” – Linda Stock

JF: As a parent, I’m opposed to the whole notion of advertising to children. I’m constantly telling my kids it’s tricks and lies. Was there any research or any debate about the whole realm of the appropriateness of advertising to children altogether?

LS: We didn’t get into that in this report. But you know that the Federal Trade Commission puts a high priority on combating deceptive advertising that harms children. For example, last year we put out a report on the effectiveness of alcohol companies’ efforts to avoid targeting alcohol to teens. You’re right to be concerned about the effect of advertising on small children. They tend to believe what they see and hear in the media. One interesting part of the research in the current report was that children under the age of seven or eight generally cannot distinguish that violence in the media isn’t real. They think it’s actually happening. So some public advocacy groups have recommended changing the ratings system. Instead of having age thirteen as the cutoff, as in the “PG-13” rating, they recommend another tier at seven or eight.

JF: Well, this is a tremendous piece of work.

LS: We’re thrilled with the report and with the positive response it’s been getting. The entertainment industry appears to be stepping up to the plate with real improvements to their ratings systems.

About Jeffrey Burman 2756 Articles
Jeff Burman represents assistant editors on the Guild’s Board of Directors. He can be reached at jeffrey.s.burman.57@gmail.com.

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