Violation Facts
Upon investigation, it was found that the defendant, Zhejiang Matao Network Technology Co., Ltd., established in 2018, primarily engaged in the promotion and operation of online games (mobile games). From November 9, 2022, the defendant posted video advertisements on the Douyin platform to promote its mobile game titled Zongheng Chuanqi. In these videos, the advertisement used phrases such as:
"Until I came across this game, where registering allows you to become a closed beta tester... This server has no recharge window... Let's open the backpack and take a look, millions of gold rewards are here (highlighted in red circle), solo players don’t need to recharge a penny... Also, we have a master-level summoning skill, try learning it. This time, I summoned 10 skeletons, all of them upgraded to skeleton warriors... You can go anywhere on the map; all maps are free..."
Consumers (players) were able to download the game via links in these advertisements. However, the actual game had a recharge feature, where consumers (players) could top-up gold (in-game currency). Moreover, players could receive additional rewards when making their first recharge, and the game also featured paid maps for members. The in-game gold rewards were far less than the millions claimed in the advertisement, and the number of skeletons summoned by the master-level summoning skill also differed significantly from what was advertised.
From November 9, 2022, to November 24, 2022 (the date the defendant took down and corrected the ad), the defendant spent a total of RMB 18,630.62 on advertising.
Administrative Penalty
Administrative Penalty Issuer: Xiangshan District Market Supervision Administration, Hangzhou
Penalty Type, Basis, and Content: A fine of RMB 60,000 was imposed on the defendant for violating advertising laws.
Penalty Compliance: The defendant must comply with the penalty within fifteen days of receiving the administrative penalty notice.
Nuocheng Commentary
This case was released by the Hangzhou Xiangshan District Market Supervision Administration as a typical example of illegal advertising in 2023. Game advertisements must be truthful and legal, adhering to specific content and publication guidelines. They must not engage in false or misleading commercial promotions that deceive or mislead consumers. It is especially important to ensure that:
Game mechanics, character designs, and scenes align with the actual product
Advertised achievements, data, and features reflect the reality
Recharge prices and promotional discounts are truthful
Draw probabilities are transparent and disclosed
While the new online gaming regulations have not yet come into effect, it is evident that regulatory bodies are tightening enforcement, particularly against deceptive marketing practices that induce consumer spending. Therefore, game companies must strictly comply with the Advertising Law and related regulations to avoid deceptive advertising and establish a robust compliance system.
