[In this opinion piece, freelance writer Ryan Rigney chats with the ESRB's Eliot Mizrachi to discuss the content disparities between Halo: Reach and Call of Duty: Black Ops, examining why both games bear an M-rating.]

I had an interesting conversation recently. A woman I know approached me asking about the recently released Call of Duty: Black Ops. Her 12-year-old son was interested in playing the game, but she was concerned that game would be inappropriate for her child, so she asked me for my opinion.

Having played through Black Ops over the weekend, I told her about some of the more violent scenes in the campaign, and informed her that in my opinion it was most certainly an extremely violent game and that it probably wouldn't be appropriate for a 12-year-old.

She then asked me about Halo: Reach. I candidly told her that while both games were rated M (the ESRB’s “mature” level rating, which indicates a game is intended for players at least 17 years of age), Reach's violence was much more subdued, with minimal blood and, thanks to the fact that most of the characters are either in suits or are goofy aliens, combat that's often more comical than cruel.

I also didn't recall hearing offensive language or seeing anything remotely sexual as I played through the campaign. With all that in mind, I told her that frankly, Reach was "probably fine" for her son to play.

The ESRB's Response

Later that day, I decided to investigate the seeming discrepancies between the shared M rating of Reach and Black Ops, so I contacted Eliot Mizrachi, the ESRB's Director of Communications. I told him the story about the mother and her confusion about the varying appropriateness of the two games, and I asked him some quite pointed questions about the ESRB and their policies. Here is the entirety of the resulting interview.

My first question for you is, why do Halo: Reach and Call of Duty: Black Ops share the same rating? Halo: Reach is listed as having blood and violence, whereas the T-rated DS version of Black Ops is listed as having "blood and gore, violence." A number of other T-rated titles have similar descriptions. Is the rating and content description on game boxes supposed to fully inform parents about the differences in content between games like Halo: Reach and Call of Duty: Black Ops, or are parents expected to visit the ESRB website before they can make a truly informed purchasing decision?

Eliot Mizrachi: What’s important to keep in mind is that there are six rating categories and thousands of games, so it stands to reason that any game is going to reside somewhere within the spectrum of a given rating category.

The ratings themselves are intended to provide a general sense of guidance for a parent, and the content descriptors that are on the package with the rating can also provide great insight into what’s in the game and where within the range of a rating category a given game may reside.

But the ratings aren’t the end-all of consumer information, which is exactly why we’ve developed rating summaries as a tool for parents that want to delve deeper and know more about specific types of content.

Our mobile website and free app allow parents to access rating summaries right from the store, where this information is often needed the most. So the ratings are a great tool, but they are only one of many that parents can and should use to make informed purchase decisions.

It’s also worth noting that even though games are often developed for multiple platforms, they may at times carry different ratings for each platform if their content differs. In fact, it’s not unusual for an M-rated console title to have a T-rated version for handhelds since that version’s content is oftentimes different – be it because of a different storyline, less graphic realism, etc.

Provided the content in a game is the same across multiple platforms, a single rating can apply to all those platform versions. But if the content differs – as it frequently does between console and handheld versions of games – each different version is its own submission and is rated separately.

Do you consider the ESRB's T rating to be equivalent to the MPAA's PG-13 rating, and the M rating to be equivalent to the MPAA's R rating?

EM: Both the Teen rating for games and PG-13 rating for movies denote that a product is suitable for those 13 and older, so in that sense they are similar. But video games differ from movies in many ways, so it isn’t necessarily an apt comparison.

The purpose of the ESRB ratings is to provide parents with information about video games they’re buying for their children and families, and what is most important is that our ratings are meeting consumers’ expectations with respect to content and age-appropriateness. The latest consumer research shows that parents are overwhelmingly satisfied with the guidance that ESRB ratings provide.

Do you think the MPAA rate Halo: Reach as R, if it were a movie? Would they rate Black Ops as R?
EM: That’s really a question for the MPAA. Our role is to evaluate each game and assign the rating that we believe best enables a parent to make an informed decision with respect to whether it is one they deem suitable for their child.

Why is it that James Bond: 007 Bloodstone has a T rating for alcohol and tobacco reference, blood, mild language, mild suggestive themes, and violence, whereas Halo: Reach is rated M for only blood and violence?

EM: Content descriptors are assigned within the context of a game’s rating category, and are not necessarily a listing of all of the different types of content one might encounter in a game. For example, an E10+ game and an M game may both have a "suggestive themes" content descriptor, but in the E10+ game this could pertain to a flirtatious remark or character’s attire whereas in the higher categories that content may be more substantial.

Or, as another example, a character drinking a glass of wine may earn an Alcohol Use descriptor in an E game but receive no descriptor in an M game since such content is relatively insignificant within the context of the game overall and the rating category assigned. I’d suggest you check out our FAQ page.

Are you aware of whether or not M-rated games have a better chance at outselling T-rated games? Does an M rating statistically improve the chances of a game selling well?

EM: Game sales have no bearing at all on the ratings we assign. However, you may be interested to know that, according to NPD data for 2009, total unit sales of Teen-rated games were approximately 30% higher than total unit sales of Mature-rated games. Our website has more information on the subject.

Can video game developers or publishers request that they be given a higher rating? For example, could Microsoft request that Halo: Reach be given an M rating instead of a T rating if the ESRB finds that it deserves to be in the "top bracket" of the T rating? Did Microsoft or Bungie in fact request that Reach be given an M rating?

EM: Ratings are assigned by ESRB raters who have no ties or contact with industry members. Game publishers have no say whatsoever with respect to the ratings we assign to their games.

What is the minimum that a game has to do to be considered an M rated game, and what is the maximum a game can get away with and still be considered a T rated game?

EM: Ratings are inherently subjective, at least to a degree, so it’s impossible to draw bright lines and make rigid rules dictating that X instances of Y content will yield Z rating. Having such rules would inhibit the raters’ ability to fully consider important nuanced elements like context, and so the ratings are ultimately determined on the basis of their best judgment with respect to a game’s age-appropriateness.

That said, the raters do consider historical parity – how similar content has been rated in the past – to ensure that the ratings we assign are as consistent as they can be, despite the fact that no two games are the same.

Why did the woman in the anecdote I gave you earlier have to come to me for advice as to whether or not Call of Duty: Black Ops is acceptable for her son to play? Why doesn't she rely on the ESRB for that information?

EM: The ESRB rating is intended as a guide, and is certainly not the only form of information available to parents. Rating summaries are a great supplemental source of information; however, ratings can’t and shouldn’t replace talking to those that are knowledgeable about games – be they friends, relatives, or game store associates who are often gamers themselves.

Although parents say that ESRB ratings are the first source of information they consult when determining if a game is appropriate for their children, word of mouth is another obvious and popular source for additional guidance.

The bottom line is that three in four parents use the ESRB ratings on a regular basis when buying or renting games for their kids, and the overwhelming majority are satisfied by the information that the ratings provide.

But a rating system can only put so much detail on the package. Checking a game’s rating is a great first step, but for parents who wish to go beyond the rating and do more research, there are great resources available to them, and we encourage parents to take advantage of them if they’re unsure about a particular game.

Am I wrong to tell a parent that Halo: Reach is “probably fine" for her 12-year-old to play, while at the same time asserting that Call of Duty: Black Ops is not okay? Why do you think she and I draw differences between the two games and their levels of acceptability when they're both rated M?

EM: Every parent has different sensibilities about what they deem appropriate for their children and families. For example, for some households violence is out of bounds while in others the major concern is profanity. The ratings are a guide that can help give parents an indication of the types of content in a game so they can make choices for themselves as to which games they deem suitable for their children.


The questions I asked Mizrachi would probably have fit better in an interrogation rather than an interview, but the ESRB has a man who's undeniably good at his job. He made a solid case for the more subjective nature of video game ratings, but I think it’s still an easy argument to make that when compared to the ESRB, the MPAA’s rating system gives consumers a more reliable system by which to predict just how abhorrent the content they’re about to view is.

Mirachi’s comment about “historical parity” carried curious connotations. He used the term “similar content,” so it’s most likely that he was referring to games with comparable amounts of violence (Gears of War vs. Bayonetta), but it could also lead one to believe that the most recently released Halo games are being rated as “Mature” simply because other games in the series were rated M as well. After all, what could be more similar in content to Halo: Reach than other Halo games?

The question I asked about M-rated games outselling T-rated games and publishers asking for higher ratings was not a baseless accusation. A 2007 study conducted by video game industry research group EEDAR found that M-rated games regularly outsell other games. Eliot’s response was that T rated games collectively outsold M rated games by 30 percent in 2009.

Unfortunately, The ESRB website shows that exactly three times more T-rated games than M-rated games were published in that same time period. Feel free to check my math on this, but that means that in 2009 the average M-rated game outsold the average T-rated game by 234 percent. That’s a pretty stunning statistic – one that smart publishers wouldn’t ignore. The insinuation here – that back-room deals are being cut to ensure an M rating, and thus greater sales – is a dark one, but Mizrachi firmly and (I believe) convincingly held that this was not the case.

It’s worth considering that if publishers like Microsoft wanted to get an M-rating on the box of their games, they could easily slip in a decapitation scene and a few “f-bombs” before sending off the game for the ESRB to review. That’d be both less shady and easier to pull off.

Also worth noting: one of the major explanations for the higher sales of M-rated games likely has to do more with current trends in what types of games are popular. Shooters in particular dominate sales at the moment, so when counting the average sales of M-rated games as a whole it's important to consider that all M-rated games are being pulled up by blockbusters like Call of Duty and Halo.

It's unlikely that tossing a random pile of offensive content into an otherwise E-rated game to get it bumped up to M will improve your sales. Still, it's valid to ask whether the Halo franchise would be the sales titan it is if it had always been rated T. Would a T rating make it easier for older gamers to dismiss Halo as "for kids," and thus move over to grittier games like Black Ops?

I’m still not personally convinced that Halo: Reach should be M-rated, but I’m also no longer convinced that the ESRB is using a flawed system. Mizrachi gave some interesting answers, but also raised questions. Are game sequels rated a certain way because of the content in previous releases as opposed to their own content? Is the ESRB as effective of a system as the MPAA? Should we expect them to be, if games are actually a more complex medium?

For the sake of context, here are the full descriptions of the questionable content in both Call of Duty: Black Ops and Halo: Reach, as provided by ESRB.org:

Call of Duty: Black Ops

This is a first-person shooter in which players control a U.S. soldier who works for the C.I.A. and participates in both well-known and secret events during the Cold War (e.g., skirmishes, stealth espionage, assassinations, and interrogations involving torture). Players use a wide variety of weapons such as pistols, rifles, machine guns, and explosives to injure/kill enemies. Combat can generate pools of blood and dismembered limbs.

Players can use enemy bodies as human shields and execute them at close range. In one sequence, broken glass is placed into the mouth of a man while he is repeatedly punched, causing blood to spill from his mouth. Language such as "f**k," "b*tch," and "sh*t" can be heard in the dialogue.

Halo: Reach

This is a first-person shooter in which players engage in futuristic battles against invading aliens. Players use pistols, sniper rifles, machine guns, grenade launchers, and swords to kill enemies during frequent and fast-paced combat. Characters are occasionally impaled on glowing swords, and aliens can be seen stabbing fallen figures during some battle sequences.

Gun fights are highlighted by realistic gunfire sound effects, explosions, and screams of pain. Human and alien characters emit spurts of blood when injured; players are able to shoot dead enemies, causing more blood to splash out. Blood is sometimes depicted on the walls and ground.