DP Tool Club 15/CD_ASCQ_15_070894.iso/vrac/rating10.zip/RATINGS.TXT

Text File | 1994-06-04 | 13KB | 259 lines

This is the text of the official position paper distributed by
ASP, STAR and ESC. Permission to copy and distribute is granted
anyone.  Only media and organizations should contact Karen Crowther
(who is overwhelmed!). Please write letters and pass this on to your
representatives, newspapers etc.

     =======================================
        _______
   ____|__     |                (R)         _______________________
--|       |    |-------------------          STAR Shareware
  |   ____|__  |  Association of                  Trade
  |  |       |_|  Shareware                       Association and
  |__|   o   |    Professionals                   Resources
-----|   |   |---------------------           P.O Box 13408
     |___|___| 545 Grover Rd.                 Las Vegas, NV 89112
               Muskegon, MI 49442-9427      _______________________

---------------------------------        Game Ratings Representative:
Educational Software Cooperative           Karen Crowther
P.O. Box 575                               P.O. Box 892
Siloam Springs, AR 72761                   Mendocino, CA  95460
---------------------------------          Voice/Fax [phone]


EXECUTIVE SUMMARY
=================

The Association of Shareware Professionals (ASP), Shareware Trade
Association and Resources (STAR) and the Educational Software Cooperative
(ESC), represent more than 2,000 software publishers, distributors and
developers.

The organizations recognize the need and benefit of proper content
labeling on computer software.  They have been developing a suitable
system for their segment of the industry, and are interested in
working with all sectors of the business to create a unified system.

They are aware of other efforts along the same lines, and are alarmed
that lack of consultation has produced proposals that are potentially
devastating the viability of their members' businesses.

Working together, they have appointed Ms. Karen Crowther to represent
the shareware segment of the software industry as a ratings standard
is developed.  Ms. Crowther is president of Redwood Games, Inc., a
shareware company known for its educational and family oriented games.


THE SHAREWARE INDUSTRY
======================

Shareware is a method of marketing software that allows consumers to
evaluate a program before paying for the right to use it.  In addition
to its traditional computer bulletin board and mail order channels,
shareware is also sold in mass-market retail stores such as Wal-Mart,
K-Mart, Caldor, and CompUSA, representing thousands of titles in tens
of thousands of locations.  In fact, the bulk of the mass-market, low-
cost software is published or licensed from shareware authors.

The creation of high-quality, low-cost software by the shareware
industry has been a fundamental force in the rapid decline in software
prices for consumers.

While the shareware industry includes many large companies, it still
affords entrepreneurs an opportunity to economically start new software
businesses.  Much of the innovation that makes America a world leader
in software originates in small shareware enterprises, and they are
key source of employment in the software sector.


PRODUCT RATINGS SYSTEMS
=======================

Recently, major publishers of videogame cartridges, led by Japanese
companies Nintendo and Sega, organized the Interactive Digital Software
Association (IDSA) to create a system to rate the sexual, violent, and
other content of computer games.  From what can be determined, they seem
to intend to expand a Sega internal cartridge-game rating system to
encompass the entire software industry by setting up a new review
organization.  This new bureaucracy would force developers to produce
expensive video presentations of their products and then pay to have the
videos reviewed before the products could be released.  It seems the
ratings would be determined by a secret panel of reviewers and judged as
to their acceptability to certain audiences.  Their system will serve the
needs and interests of cartridge manufacturers very well.  No
consultation outside of the IDSA is known to have taken place.  This
system is in the formative stages.

A working committee of the Software Publishers Association (SPA) is
developing a content-based rating system that would uniformly disclose
the existence of objectionable matter in software products.  The system
utilizes "registered disclosure" to record certifications by the
publisher as to the product content - affording strong legal protection
for consumers while significantly reducing the size and cost of
administering the system, and eliminating delays that could have dire
consequences for the publishers and retailers.  The SPA is consulting
with its membership and has been actively soliciting input throughout the
industry.  This system is in the formative stages.

The shareware industry is developing a content-based rating system with
specific parameters that allow products to be pre-rated at the developer
level.  This allows developers to avoid specific content that would
result in more severe ratings.  The rating system allows for internal
tagging of programs to allow them to be scanned for content, making the
system suitable for use in the coming "information superhighway" and
provides for future software locks that would allow schools and parents
to "lock out" software that falls outside their self-determined
parameters.  The system capitalizes on existing packaging and advertising
statutes to provide for strong sanctions against developers that may
mis-rate their products.  The system eliminates delays, nearly
eliminates administrative costs, and meets the needs of developers,
publishers, parents and children.  The system has been developed with
the input of hundreds of developers, using information from the IDSA,
the SPA and congress, and is near completion.


CONCERNS WITH IDSA PROPOSAL
===========================

The associations recognize that the key IDSA players (Nintendo, Sega, and
Electronic Arts) are the largest companies in the cartridge games industry.
As currently composed, the IDSA has only a dozen members, representing
the narrow interests of only the few dozen existing cartridge game
manufacturers and is designing a system to meet only their own needs.

Although the IDSA proposal will be an easy step for cartridge game
manufacturers, it's clearly harmful or potentially fatal to over 1,000 SPA
members and over 2,000 ASP, STAR and ESC companies - the bulk of the entire
software industry.  None of these companies have any representation in the
IDSA.

The associations were especially alarmed to discover that Senators Kohl and
Lieberman have already begun to approach the customers of our members.  In
letters to our most important and valuable accounts, the senators
encouraged them to refuse to purchase our members' products unless rated by
the IDSA.  If successful, this could force many of our members out of
business as they are faced with a choice of submitting to an inappropriate
and damaging review process (one which they had no voice in shaping) or to
lose their customers altogether.

There are a number of areas that the IDSA will need to address before
their cartridge-game rating system can be expanded to other software
formats and to smaller companies.

Review Delays
-------------

Cartridge game manufacturing cycles include lengthy periods for tooling
and production, requiring many months of advance planning.  The cartridge
segment also produces only few hundred new products each year.  These
factors keep the volume of products to review comparatively low and
negate the impact of reasonable delays for product review.

Our members release hundreds of new products each week, and the number
of shareware games already in distribution currently exceeds 10,000
For the IDSA's committee to review all of these within 7 days, as it
proposes to do, is not realistic.  The associations feel that the IDSA
has not taken this into account and so has no realistic plan to deal with
the volume.

If implemented, the IDSA's system would immediately create a huge backlog
of games to be reviewed, greatly slowing the entry of new games into the
market.  This would intolerably burden an industry whose strength lies
partly in innovation and in the quick exploitation of market niches.

Adequately addressing this (within the framework of a review panel) will
require the commitment of millions of dollars to staff and equip a
bureaucracy of magnitude not yet realized by the IDSA.

Unlike the game-cartridge segment, the PC software producers have time
lags between product completion and production that are frequently
measured in hours.  During the critical fall season, a two- or four-
week delay could be catastrophic to many of our members.

Cost
----

The IDSA has indicated that the $500 fee for a rating is a subsidized
cost and that, to be self-supporting, its system will require more
funds.  In the context of the wildly unrealistic volume expectations
of the IDSA, it can reasonably be expected that the eventual cost will
be many times this amount.

Under the IDSA plan, submissions for review would be done on videotape.
For cartridge games (which connect directly to TV's and VCR's), this is
straightforward and quite inexpensive.  For PC games, capturing video
and sound on videotape requires the use of costly special video equipment
that many shareware companies can't afford.  Add to this the reasonable
administrative costs in time and manpower for the developers to process
their applications, and it's not unreasonable to anticipate costs
running into the thousands.

This cost will fall most heavily on the children's educational games
since these games sell only one third the volume of adult games.

To large cartridge-game manufacturers, this is pocket change.  To many
of our smaller members, it is more than an entire month's income, and
would make their continued business operations impossible.


Variants
--------

While the cartridge game companies rarely make changes to a game after
it's released, upgrades and variants are the very lifeblood of the PC
market.  Products are frequently re-released several times with
improvements in art, sound, game design and coding.  In the shareware
market, this is particularly prevalent with several dozen new releases
of a product over its lifetime.  These are extremely important to the
long-term viability of a product (and a company) in our market.

The shareware industry is also unique in its non-exclusivity.
Developers frequently release the same basic product (with cosmetic and
sometimes content changes) in many different variants to many different
publishers.

The IDSA proposal makes no allowance for these common occurrences and we
fear that this will multiply the costs of the IDSA system to our
members.


CONCLUSION
==========

The membership of our organizations recognize and support the
implementation of objective content labeling standards for computer
software.  They are interested and willing to work with other segments
of the software community to establish a workable and useful system.

They are deeply concerned that they have not been represented in the
development of the system that the senators are now promoting, and are
unhappy that their legitimate business needs have been neither heard
nor addressed.

They have profound reservations about being saddled with an ill-conceived
and economically nonviable cartridge-game system, created and controlled
by only a dozen large companies from only one small segment of the
industry.

The ASP, STAR and ESC are creating an objective, content-based, self-
rating system which can be implemented under the auspices of the three
organizations.  Our goal is a system that can provide helpful information
in a manner that is consistent and meaningful, and that does not unduly
interfere with anyone's ability to market their products.

We plan to inform the IDSA and SPA of our progress, and hope to join them
in a single standard.

We have grave concerns about the apparent possibility of placing control
of this important aspect of our business in the hands of an association
controlled a handful of very large companies - companies who have no
understanding of our part of the industry or empathy for small enterprises.

We believe that when the videogame corporations, the public, and Congress
better understand this and the importance of shareware to the games market,
they will support us in our desire for an effective, viable ratings plan.

FOR MORE INFORMATION, CONTACT: Karen Crowther, P.O. Box 892,
Mendocino, CA 95460, Voice/Fax [phone].