Letter to the ESRB

This morning I tried giving the ESRB some feedback of their recent change to the rating of Oblivion from Teen to Mature. Unfortunately, the form on the ESRB site only allows you to type up to 500 letters, a ridiculous constraint. I went ahead and sent them a note anyway, but here’s the letter that I wanted to send.

I think you’ve made a big mistake with the re-rating of Elder Scrolls IV: Oblivion.  I’ve played the PC version for more than 50 hours and haven’t encountered any content that should qualify it as “Mature”.

Here’s how your website defines Mature:
Titles in this category may contain intense violence, blood and gore, sexual content and/or strong language.

Let’s see… intense violence.  No, not really.  Sure, it contains violence, but it’s not really so intense that a teen shouldn’t be able to play.  Starcraft is far more intense and contains longer durations of violence, but is rated Teen.

Blood and gore.  I have seen blood, but it’s not particularly gory.  The wounds aren’t realistic, and blood doesn’t flow out of bodies.  Sure, there’s a brief mist of blood in the air when you hit someone, but it’s very realistic — more like a hint of blood.  Probably the goriest thing I’ve seen so far have been the bloody handprints on the doors in the Arena.  I can’t imagine how a teen would be troubled by the hints of blood in this game.

Let’s get strong language out of the way.  There is none.  That’s all there is to it.

Sexual content gets trickier.  The game itself doesn’t seem to have any sexual content — certainly none that I’ve seen or heard about.  You specifically state that Oblivion contains nudity.  Again, I haven’t seen or heard any.  From the rumors I’ve read, you’re counting modder’s content in the game.  Yes Oblivion can be modified so that when characters are undressed they’re nude.  It doesn’t come like this standard, and the XBox 360 can’t even be modded.  Most importantly, nudity doesn’t equal sexual.  It’s a good thing you guys don’t rate coloring books.  Who knows what people might draw between the lines!

I’m not too worried about Bethesda or Elder Scrolls.  I doubt this will hurt their sales too much, and the added publicity might even help.  I’m more worried about you.  You’ve just lost huge amounts of credibility as far as I’m concerned.  Based on the blog posts I’ve seen, I’m sure most gamers feel the same way that I do.  You’ve really gone overboard here.  The only way to regain any credibility would be to admit you made a mistake a reverse the rating change.

Sincerely,
Aaron McBride

One Response to “Letter to the ESRB”

  1. aaron Says:

    Here’s the reply that I got from the ESRB:

    Thank you for contacting the Entertainment Software Rating Board with your comments regarding the re-rating of The Elder Scrolls® IV: Oblivion(tm). This is a serious and complex issue, and we sincerely appreciate your concern.

    Following the public release of Oblivion, and as a result of ESRB’s post-release monitoring and play-testing activities, the ESRB learned of the presence of two separate types of content that were deemed legitimate cause for reconsidering its rating. The first was depictions of blood and gore that appeared to exceed in detail and intensity that which was submitted to ESRB during the rating process. The second was a third party modification to the PC version which unlocked an art file already present in the code of the game, allowing players to apply a topless model or “skin” to female characters.

    These issues moved the ESRB to initiate a review that involved:

    * Comparing the material disclosed in the game’s submission by the publisher to content that was captured during an ESRB test of the final product;
    * Verifying that the locked-out content was in fact in a fully rendered form in the code of the PC version of the game, and confirming the means to unlock it; and
    * Submitting the original submission materials for the game along with the content captured during ESRB testing of the final product for review by ESRB raters to evaluate the accuracy of the initial rating assignment.

    This review confirmed that the company’s submission for Oblivion understated content with respect to the blood and gore found in the game. Specifically, the depictions of blood and gore were found to exceed the detail and intensity of those included in the publisher’s videotape submission, and to be inconsistent with a Teen rating. The ESRB raters’ review resulted in their assigning the game a rating of M (Mature) for blood, gore and nudity, rendering the initial T (Teen) rating inaccurate.

    The ESRB also verified that the code in the PC version of the game contained a locked-out topless female character model that, though programmed to be inaccessible, could be unlocked through the use of a third party tool. The skin associated with this content was found to exist in a fully rendered form on the game disc, and to require only a minor modification to a filename in the code of the PC version to access (the Xbox 360(tm) version of the game cannot be modified to unlock the skin).

    ESRB rules require that publishers disclose locked-out content during the rating process if it is pertinent to a rating. Accordingly, all skins included in the code on the final Oblivion game disc are considered pertinent to the rating, whether accessible through normal game play or not. The topless female skin was not disclosed to ESRB during the rating process.

    As a result of these findings, the ESRB changed the rating for both the PC and Xbox versions of The Elder Scrolls IV: Oblivion from T (Teen) to M (Mature). The PC version of the game will carry an additional content descriptor for Nudity until a new version of the game can be re-mastered, replicated and released. Since the ESRB investigation confirmed that the Xbox 360 version cannot be modified to access the topless skin, the Nudity descriptor was deemed unnecessary for that version.

    It is inevitable that some may disagree with the ESRB’s actions in this instance. We simply ask those who disagree to consider that consumers, especially parents, count on ESRB ratings for reliable and accurate information about what’s in a computer or video game. They deserve to know what they are buying, and the ESRB is both obligated and committed to providing the most reliable and accurate ratings information possible. If content that would affect a rating is left on a game disc, even if it is not intended to be accessible during normal gameplay, it must be considered in the assignment of that rating. On the other hand, many mods actually introduce new content into a game that was created by a third party and not the publisher. These mods are beyond the publisher’s control, and therefore cannot reasonably or practically be considered in the assignment of ratings.

    The strength of our self-regulatory system lies in its unique ability to independently evaluate publisher compliance with a wide variety of industry-adopted rules and regulations, and enforce instances of non-compliance. The interests of parents, gamers, and other consumers are best served by having an effective self-regulatory body, whose actions are objective, judicious and fair. We appreciate your taking the time to express your opinion on this issue, and hope that you better understand our actions.

    Regards,

    Entertainment Software Rating Board

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