Legal definitions of gambling
Much of the public debate regarding loot boxes has centred on whether such
micro-transactions constitute gambling, and should therefore be regulated
accordingly. This debate has focussed on the legal definition of gambling under
federal and state and territory legislation; and the definition of gambling
according to psychology.
This chapter will outline the legal definitions of gambling at the
federal, state and territory level and the views of regulators tasked with
determining the application of such legislation to loot boxes. The evidence
received from witnesses, both for and against the application of gambling
regulation to loot boxes is canvassed. This chapter also outlines the responses
from international regulators.
The evidence regarding the psychological definition of gambling will be
explored in Chapter 3.
Commonwealth regulation of gambling
The regulation of gambling in Australia has traditionally been the
responsibility of the states and territories rather than the Commonwealth.
State and territory governments regulate and provide gambling services, and collect
the ensuing revenue. However, given the nature of services provided via the
internet, the Commonwealth has been given responsibility for the regulation of
interactive gambling services in Australia through the Interactive Gambling
Act 2001 (the IGA). As such, the IGA defines a gambling service as:
(e) a service for the conduct
of a game, where:
- the game is played for money
or anything else of value; and
- the game is a game of chance
or of mixed chance and skill; and
- a customer of the service
gives or agrees to give consideration to play or enter the game.
Ms Jonquil Ritter, Executive Manager, Content Safeguards Branch,
Australian Communications and Media Authority (ACMA), told the committee that
the IGA prohibits the provision of certain services to customers in Australia.
Ms Ritter stated:
The IGA prohibits certain services from being provided or
advertised to customers in Australia. These include: online gambling services
for games of chance, or games of mixed skill and chance such as casino-style
games like blackjack and roulette and online slots. Since the IGA was amended
in September 2017, the ACMA has had responsibility for enforcing the
prohibitions on providing or advertising illegal interactive gambling services.
We also have a role in raising awareness of Australian gambling laws to help
minimise the supply and use of illegal interactive gambling services.
Examples of prohibited interactive gambling services include online casino-style
games, online slot machines and online wagering services that accept in-play
bets on sports events. Regulated interactive gambling services are those
services excluded from the definition of a prohibited interactive gambling
service, and this includes online wagering services (other than those offering
in-play betting). These services can only be provided to customers in Australia
with a licence granted by an Australian state or territory licensing authority.
The ACMA explained that online games, including those which contain loot
boxes, have not, to date, been regarded as gambling services under the IGA 'because
they are not 'played for money or anything else of value', as set out in
paragraph (e)(i) of the definition of 'gambling service''. The ACMA stated:
...a video game is typically played for
recreational purposes, rather than with the
object of winning money or other valuable items. Loot boxes in
turn are generally not used for the object of winning money or other valuable items, but for other reasons, such as to
aid progression through a game or enhance
aesthetic characteristics of the gameplay.
The ACMA submitted that many of the items that are redeemed from loot
boxes do not have any monetary or other value, and stated that in those
circumstances, a loot box clearly cannot meet the definition of a gambling
service. Ms Jeanette Knowler, Manager, Interactive Gambling Taskforce, ACMA, also told
the committee that the Explanatory Memorandum for the IGA when it was
introduced in 2001 states that a game must be played for a prize of monetary
value for it to meet the definition of gambling under the IGA.
The ACMA however, noted that 'there may be cases where the position may
not be so clear, particularly where there is a secondary market for items'. As
a regulator, the ACMA is required to consider the particular features of a game
or service and that it is 'therefore difficult to make statements about
"loot boxes" or video games generally'.
The ACMA further noted that even where a service or game may meet the
definition of gambling, it does not necessarily mean that it is prohibited
under the IGA. The ACMA stated that the 'definition
of "gambling service" is
only one of the matters the ACMA must consider in deciding if a service is prohibited under the IGA'.
State and territory regulation of gambling
Gambling is also regulated by the states and territories and as such,
the committee received submissions from the Victorian Government, and the New
South Wales Government. These submissions outlined whether loot boxes meet the legal
definitions of gambling under the legislative frameworks in these states. For
example, the New South Wales Government submitted that:
Liquor & Gaming NSW does not consider that purchased loot
boxes and other chance-based items (which can include a key to unlock a loot
box) by themselves constitutes gambling under NSW gambling laws. However,
Liquor & Gaming NSW is aware of particular instances where virtual items
(being quite often the contents of a loot box) can be monetised outside the
game they are featured in. Such instances are likely to offend NSW gambling
laws, depending upon the circumstances.
The New South Wales Government explained that under the Unlawful Gambling
Act 1998 (NSW) (UGA), the definition of what constitutes an 'unlawful game'
includes a requirement that 'money is staked or risked on an event or
contingency'. The New South Wales Government explained that money being staked
or risked covers the 'prize element' in a general way and that anything that
has monetary value would meet this requirement. As such, loot boxes which
cannot be cashed-out or monetised outside the game would not meet the
definition under the UGA. The New South Wales Government explained:
Where a game allows a player to purchase loot boxes and other
chance-based items found in video games, which then provides a virtual item
which can be used by the player as a form of currency outside of the
game (thereby having monetary value), Liquor and Gaming NSW would regard this
as satisfying the third limb above and this is likely to contravene the UGA.
The New South Wales Government also stated that the NSW Responsible
Gambling Fund is currently considering the risk of gambling related harms
associated with in-game micro-transactions and chance-based items, including
loot boxes. This work will inform the NSW Government's approach to whether
additional safeguards are required to address the concerns around normalising
gambling to minors through loot boxes.
The Victorian Government however submitted that the definition of
gambling under the Gambling Regulation Act 2003 (Vic) means that loot
boxes must be considered on a case by case basis to determine whether they meet
Submissions from state governments also raised concern that despite
states and territories being responsible for the regulation of gambling in
their jurisdictions, the nature of online gaming makes it necessary for
regulation at a national level. The Victorian Government stated that 'state and
territory governments are limited in their capacity to regulate products that
are available exclusively online, are offered from outside their jurisdiction
and do not constitute gambling'. The Queensland Attorney-General and Minister for Justice, also highlighted
...many game developers, including the developers of games at
the centre of recent loot box controversies, are based overseas and have global
markets...games may be purchased, patched and played via digital distribution
platforms located on servers outside the jurisdiction in which the player
resides. Additionally, from an Australian perspective, multiplayer games,
including those games involved in recent loot box controversies, are generally
played on oceanic servers that combine players from multiple Australian
jurisdictions (and the wider oceanic region) in a single game.
The Queensland Attorney-General and Minister for Justice, while not
commenting on whether loot boxes meet the legal definition of gambling under
Queensland law, nevertheless concluded that any regulation of games containing
loot boxes through amendment to the IGA 'would appropriately reflect the
Commonwealth's responsibility for online gambling and ensure consistent
implementation of any relevant intervention across all Australian
Issues raised in evidence
The following sections outline the evidence received both for and
against the argument that loot boxes constitute gambling, as they relate to the
legal definitions of gambling.
Submitters that argued loot boxes do not constitute gambling under
Australian legislation reiterated the position outlined by the ACMA, namely
that games that involve loot box features, have not been regarded as gambling
services under the IGA, because they are not played for money or anything else
of value (i.e. the requirement established by the IGA). For example, the Interactive
Games and Entertainment Association (IGEA) submitted that:
Because items for loot boxes cannot be lawfully cashed out or
exchanged for real world money, they do not involve an offer of prizes of money
or "other consideration of value" and so do not constitute gambling.
Mr Ron Curry, Chief Executive Officer, IGEA, told the committee that
'the items obtained are not money or considered as items of value, as they are
only useable within the games and cannot be cashed out within those
However, others argued that the legal definition of gambling is 'outdated'
and has not evolved to keep pace with technological developments. Mr Jeremy
Ray, for example stated that the 'legal vocabulary to deal with the myriad
iterations of loot boxes out there' does not exist. Further, there is not a
'stringent enough qualification, in a legal sense, to define gambling'. Mr Ray
suggested that a 'practical definition of gambling is simply putting up value
for a random amount of value' and that in the case of loot boxes, 'it's no
secret that people are willing to buy virtual goods, proving their value. Thus
loot boxes meet that definition every time, whether cosmetic or
The concept of a commonly-accepted definition of gambling was reiterated
by individual submitters who described the concept of loot boxes where players
purchase the chance to win an item, and where that item is unknown and likely
to be of low value as 'blatant gambling'.
Always a prize
It was also argued that loot boxes do not constitute gambling because
players are always guaranteed to receive in-game content when they make a
purchase i.e. there is no loss incurred by a player. For example, IGEA
submitted that 'players will not encounter a scenario where the purchase of a
loot box does not result in the player obtaining an in-game item'. IGEA argued
that this distinguishes loot boxes 'from gambling services such as poker
machines, where users are not guaranteed to receive anything in return for
Dr James Sauer and Dr Aaron Drummond (Sauer and Drummond) noted that
international jurisdictions have cited this argument when explaining why loot
boxes do not constitute gambling. Sauer and Drummond submitted:
...everyone who purchases a loot box gets something so
there are no losers. An obtained reward might be high or low in value (or
desirability) but, unlike in more conventional forms of gambling, no one loses
their money entirely. Both the ERSB (the game rating agency for US and Canada)
and PEGI (Pan European Game Information; the game rating organisation for Europe)
have cited this argument when explaining their view that loot boxes are not a
form gambling (Griffiths, 2018).
However, while Sauer and Drummond described this premise as 'accurate'
they noted that with loot boxes, 'some players still lose'. Sauer and Drummond
explained that players may lose in one of two ways. First, the functional
utility of reward items varies markedly with some items offering substantial
competitive in-game advantages, while others provide no advantage. Players who
receive these competitive advantages 'win' whilst those who do not, 'lose'.
Second, where items can be sold on third-party websites, the market value for
some items is less than the cost of purchasing the loot box. Therefore, the
item is worth less than the amount of money the player expended in obtaining
it, and the player incurred a financial loss as a result of the loot box
Other submitters described the defence that there is 'always a prize' as
'highly disingenuous' and agreed with Sauer and Drummond's assessment that
prizes are often of little or no value. Mr Jeremy Ray explained:
Often what you get back is of minuscule or zero value, and
often it's a duplicate of something you've won before. The odds of winning
anything of high value are carefully calculated not only so the house always
wins, but so the player feels like they've always almost won.
The Australian Institute of Family Studies (AIFS) similarly submitted
that players take a risk when purchasing loot boxes and loot boxes are much
more likely to contain a common item of low or no in-game value, which may
represent a monetary loss to players. It stated:
Gambling requires an individual or group to risk losing
something of value (in the case of 'loot boxes', money is risked) on an event
with an uncertain outcome (a 'loot box' containing a random item is received)
with the aim of winning something of greater value (although, in reality the
'loot box' is much more likely to contain a common item of low or no in-game
value, which may represent a monetary loss; a valuable or highly sought-after
item is rarely received).
The Institute concluded that on that basis 'micro-transactions for
chance-based items therefore fall within the definition of gambling provided in
the Interactive Gambling Act 2001 or, indeed, in any commonly-accepted
definition of gambling'.
Sauer and Drummond also expressed caution that the position that 'there
are no losses because everyone receives something' could lead to unintended
legal consequences. Sauer and Drummond submitted:
Accepting the argument that nobody loses in these games because
'everyone receives a prize' may set a legal precedent for illegal gambling
operations more broadly (e.g., unlicensed casinos) to skirt gambling
regulations by providing every player with some prize following a losing game
(e.g., by giving losing players 5 cents of their money back on a losing
Dr Drummond concluded, 'we do see a significant legal hazard with this
idea that everybody wins when in some cases there are clearly real-world
financial losses occurring from those loot boxes'.
Surprise and delight
It was argued that loot boxes do not constitute gambling because they
are simply 'surprise and delight' mechanisms similar to trading card games and
Kinder Surprise Eggs, in that purchasers understand that they are buying an
item but remain unsure of the item's details until they open the packaging. IGEA
Retail and toy stores also stock a significant number of
products that allow consumers to purchase sealed, non-transparent boxes or
crates that provide unknown items on a variable basis...the use of surprise and
delight mechanics in consumer products is pervasive and thus is not something
unique to loot boxes.
Mr Curry, IGEA told the committee that loot boxes are 'a mechanism
that's been used for many years across many different forms of product'. Mr Curry
...look at things like trading cards, you don't know the value
of what you're going to get out of them. You could get cards very similar to
those you already have or you could get the gold, silver, bronze or whatever it
is. The mechanic that we were explaining is not new and is not unique to video
However, this argument was rejected by a number of witnesses for a range
of reasons including the effect of the context in which a player engages with
the mechanism, and the knowledge of the item contained within. For example,
Professor Elizabeth Handsley, President of the Australian Council on
Children and the Media (ACCM) told the committee that:
The one really significant difference between loot boxes and
the two types of systems that you've just referred to [Kinder Surprises and
sports trading cards] is that loot boxes operate in a context where a player is
already highly committed to a game...and is therefore likely to experience much
greater pressure to purchase the loot box and wants something that's in the
loot box in order to progress in the game where that person is already highly
Professor Handsley went on to explain that the psychological process of
deciding to engage with a Kinder Surprise is different to the psychological
process made when a player 'is in the middle of playing a game and...needs a
particular tool or feels that a particular tool or weapon would be particularly
useful at that point in the game and therefore tries to get access to that tool
Submitters also argued that before purchasing a Kinder Surprise egg or
trading cards, consumers are broadly aware of the value of the item and that
this is different to the process of engaging with a loot box.
Monetisation of virtual items
A number of submitters argued that the position taken by regulators that
'in-game rewards have no real-world value, therefore loot boxes are not
gambling' ignores the evidence that a number of games allow players to buy and
sell virtual items for real-world currency. For example, Sauer and Drummond submitted that during an examination of 22
games released in 2016 and 2017, they found that more than one-in-five allowed
players to cash out winnings. Dr Drummond told the committee that:
Often this occurred on third-party websites, but in at least
one case in the games we analysed, and in at least four other cases we can
cite, it actually occurs through a primary marketplace that is connected to the
distribution platform of the game. There are actually quite substantial rewards
associated with that. We're talking about the possibility of receiving rewards
from these loot boxes that can be cashed out on those primary marketplaces
for...Real-world currency. Upwards of US$1,800 is what one of the items was
listed for last week.
The rarity of some in-game items, and the emergence of online sites
acting as exchange markets (e.g. OpSkins and CSGOlounge) have led to players
paying high prices to purchase virtual items. The AIFS described in-game items
as acting as 'de-facto virtual currencies'.
The monetization of virtual items, that is, the embedding of loot boxes
in the real-world economy can occur in a variety of ways, as outlined below.
- Platform supported sale – some game creators and
storefronts allow virtual items to be traded between accounts through digital
marketplaces that involve either real-world currency, or digital currencies
that can be used to purchase things that have real-money value. For example,
games publisher Valve allows virtual items to be traded through its Steam
storefront for store credit which can be spent on games by other publishers.
Currency can also be indirectly traded between users.
- Platform supported trade – some games allow virtual items
to be traded between accounts within the game, often using in-game
marketplaces. Theoretically, no-real world currency is utilised in the
transaction, however users may communicate and real-world currency is then
exchanged outside the game in exchange for the transfer of the item for a
symbolic in-game price.
- Account exchange – some games lock virtual items to a
user's account which prevents the trade of items between users. However players
who obtain a particularly rare or valuable item through a loot box can offer to
sell their account to another player (using real-world currency exchanged
outside of the game) to allow the other player to play the game using the rare
- Third-party sales – third-party companies commonly
referred to as 'gold farmers' rapidly obtain virtual items with in-game value
and sell them to other players for real-world currency. The products offered
may include items where the cost of obtaining the item is lower than the
average selling price for the item. Gold farmers do not participate in 'normal'
or 'for fun play' and are therefore able to obtain game resources more rapidly
than recreational players.
- 'Skin gambling' – players use virtual items and loot boxes
as pseudo-currency on third-party gambling sites. These sites are not approved
or authorised by games developers or publishers.
In examining loot boxes, international researchers Rune Nielsen and
Pawel Grabarczyk, developed a typology for distinguishing loot boxes according
to whether they are isolated or embedded in real world economies. This analysis
examined whether the resource required to obtain the loot box involved
real-world currency (embedded) or in-game resources (isolated); and whether the
reward/virtual item can be monetized in the real world economy (embedded) or if
it can only be redeemed within the game (isolated).
Table 1 – Types of loot boxes
Source: Dr Marcus
Carter, Submission 11, p. 2
Dr Marcus Carter highlighted that Nielsen and Grabarczyk argue that the
fourth (fully embedded) type of loot box is 'functionally similar to gambling',
noting the exceptional amounts of money involved (i.e. loot boxes which cost
very little to purchase, deliver items which can be sold for thousands of
dollars). Dr Carter stated that 'this is also useful for distinguishing between
collectible cards and loot boxes'.
The committee heard that the Steam marketplace, offered by the game
developer, publisher, and digital distribution company Valve, allows digital
items to be traded between players for real world currency, with the original
creator of the digital item collecting a fee every time the item is traded
between players. Mr Blake Mizzi, Board Member, Game Developers'
Association of Australia (GDAA), told the committee that Steam 'seems to be
quite a healthy marketplace' where 'we see a lot of healthy transactions
Dr Drummond highlighted that the retail value of virtual items obtained
through the purchase of loot boxes on Steam can vary hugely with items sold for
a few cents while others are sold for thousands of dollars. This means that
players are able to make a profit, or suffer a financial loss through the
monetization of virtual items. Dr Drummond told the committee:
The overall message I'm trying to convey...is that...the highest
cost items are being sold for US$1,800, for example, one of the items on the Counter-Strike:
Global Offensive market. The lowest cost items are often been sold for
about 3c, and the cost of a loot box is typically around $2.50, so we're
looking at real world gains of $1,800 and real-world losses of up to $2.47 per
entry into this loot box.
Drummond and Sauer submitted that for loot box systems where players can
'cash out' in-game rewards for real-world currency, they should be considered
to meet the 'common legal criterion to be considered gambling' [i.e that prizes
have a monetary value].
Ms Knowler, ACMA, agreed that as a regulator examining 'whether or not
something fits within that definition [of gambling] is less problematic when
you can monetise the item on a secondary market'. Ms Knowler noted that this definitional
approach has been adopted by some international jurisdictions. However, Ms
Knowler also reiterated the evidence provided in the ACMA's submission, that
loot boxes must be examined on a 'case-by-case basis and there are quite
different facts and ways of playing each of these games'.
IGEA submitted that it accepts that if game publishers or developers
authorise the sale or exchange of virtual items for real-world currency, then
the legal definition of gambling under the IGA would likely be met. It commented:
IGEA accepts that if game publishers or developers authorised
players to cash out, transfer or gamble items acquired through loot boxes for
real currency, whether directly or via external websites and services, the
element of "offering prizes of money or other consideration of value"
would likely be satisfied and current Australian gambling laws may be
activated. This might also implicate the gambling laws of other countries and
anti-money laundering legislation.
IGEA concluded however that it is 'not aware of any video games that
engage in this practice'. Mr Ron Curry, IGEA explained that 'video game publishers and developers
typically do not allow loot boxes, virtual items or game points to be traded,
exchanged, sold or gambled outside of the game ecosystem or via third-party
sites'. Mr Curry stated:
Where a party other than the video game publisher, developer
or platform offers a mechanism to cash out, purchase or gamble, it's generally
unauthorised, potentially unlawful and likely acting in violation of the terms
of service and user-licence agreements, and other similar contractual terms.
Video game companies do not receive any benefit or remuneration from these
external websites or services, and nor do they have any relationship with the
companies that operate them.
IGEA also questioned whether the monetisation of virtual items for
amounts higher than the purchase price should determine whether a loot box
meets the definition of gambling. It highlighted that items obtained through
other 'surprise and delight' mechanisms such as trading cards and toys can also
be sold for more than the purchase price. IGEA submitted that:
...collectible items frequently sell at prices that are
marked-up much higher than their initial recommended retail prices. Does this
mean that these products also constitute a form of gambling or require
additional regulation, simply because the initial purchase involved an element
of variableness and surprise?
It was acknowledged that virtual items are also able to be monetized
through so-called 'skin gambling' where virtual items are used to 'chip in' on
online digital casinos. However, this was described as occurring in 'a dark
corner of the internet', and without the permission of game developers or
publishers. Mr Mizzi, GDAA, stated:
Essentially, we do know that
there is a dark corner of the internet where gambling goods in video
games—digital goods from video games, as in these digital casinos—is a problem.
It's a billion-dollar industry. A lot of these individuals, as I mentioned before,
are based in Russia and often in the US as well. There have also been
indications that this has also been connected to money laundering. But they're
not part of the common or mainstream games industry or community of players.
IGEA submitted that 'black' secondary market websites utilise 'underhand
tactics to be able to operate, including setting up fake accounts to facilitate
external trades, hacking or exploiting vulnerabilities in a game environment,
or even transferring ownership of accounts to other players by password
Mr Mizzi, GDAA, told the committee that Valve's Steam platform has been
the principal platform utilised by third party gambling sites. Further, despite
Valve's attempts to close such sites, new ones are created daily. Mr Mizzi
Valve has been on a mission to clamp down on these third
party skin casinos and has managed it around their popular game Counter Strike
GO. This has been made possible due to a gap or a loophole identified in the
Steam platforms open ID API—it's part of their programming—and has created a
billion-dollar black market gambling industry... As I understand it, Valve has
managed to close roughly half of these casino related gambling sites though new
ones do open daily. For the committee's benefit, Valve is a privately-owned US
company that is the creator of the Steam marketplace platform and is also the
creator of the CS:GO game.
Mr Mizzi concluded that the issue of skin gambling using the Valve
platform is not an issue related to game design or the inclusion of loot boxes,
but rather it is 'a security problem' related to the Valve platform.
Mr Mizzi also stated that game developers have little control over third
party gambling sites, or the security measures utilised by digital stores which
sell games. In addition, few options are available to game developers when
users breach terms of service or licence agreements to skin gamble.
Mr Mizzi stated:
The game developers around the
world, particularly Australian developers, who publish their games on digital
stores such as Steam, Xbox, PlayStation, Google Play and the iTunes App Store
have little to no control over the security measures or the code and
infrastructure around these digital stores. We also don't have much control
around the third party gambling sites. And we have only limited control around
when a player breaches our users end term licence agreement or terms of
service. One way the players can cash out in this regards has been
identified—when they sell their online account to someone else.
Broader concept of value
While the ACMA submitted that it is restricted by the requirement of the
IGA that prizes must have a monetary value in order for loot boxes to satisfy
the legal definition of gambling, other submitters argued that this 'rests on a
very narrow conceptualisation of utility'.
Sauer and Drummond argued that this position 'ignores the subjective
value created for players from the combination of scarcity of, and competitive
advantage provided by, in-game items in the gaming environment'. Sauer and
...in-game rewards can have value for players – and influence players'
behaviour (i.e., motivate them to engage with loot box mechanisms) – without
being converted into real currency. For example, a scarce costume may signify
prestige in the games' online community, or a particular weapon might be highly
desirable because it increases the ease with which they can win future games.
In both cases, the item has value for the player, and this value may motivate
players to continue buying randomised rewards until they obtain the item they
Dr Drummond told the committee that 'most games have variable scarcity
items that are often referred to as rare, epic or legendary items'. These items
are often only ever given to players a very small percentage of the time and
this creates a system where players desire these items more than other items.
Dr Drummond concluded that the desirability of an item alters the way a player
'might perceive the value' of items.
Professor Handsley, ACCM, similarly highlighted the psychological
processes which affect the way in which players conceptualise value. Professor
Handsley argued that the ability to:
...convert loot boxes into
real-life money is neither here nor there because the items that are accessed
via loot boxes are of value to the player. That's all that really matters from
a psychological perspective. Whether that person can then get money or some real-life
tangible good in return for the loot boxes is neither here nor there. The
player is committed to the game. These games are very absorbing. There are a
lot of people who have a lot invested in playing games and getting to higher
levels, therefore the value to those can be very high. Form a psychological
perspective, that's what matters. Whether it's money or some tangible good is
really not the point.
The Attorney-General and Minister for Justice (Qld) also noted that
virtual items obtained through loot boxes 'can change the way the player is
perceived by other players within the game, therefore adding to the player's
prestige and status and creating something of value to the player'.
Similarly, Dr Carter highlighted the finding by the Belgian Gaming Commission
that 'loot boxes are a form of gambling, even if players can't trade or sell
the options'. The Commission found that 'what is important is that players
attach value to it [loot boxes] and that this value is also emphasised by the
game developers themselves'.
It was also noted that this broader conceptualisation of value and
utility may have particular effects on children. For example, Dr Carter noted
that children, 'who do not place the same value on "real" money as
adults' may be 'more vulnerable to the configuration of economically isolated
rewards that have significant social and cultural value to players'. For
example, being able to play as Cristiano Ronaldo in FIFA or advantages
in competitive games such as Angry Birds 2, may have more value to
children than a monetary prize.
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