Note on Online Ecosystem, its challenges and solutions

1. Introduction
The advent of India’s online gaming industry started when console and PC gaming brought
several middle-income group Indians on digital gaming platforms, during mid 2000s which
was largely in the form of social games. With the rise in internet penetration and increase in
smartphone user base, being online & easy access to online games has realised the impressive
market volumes due to proliferation of low cost smartphones amongst urban and rural
population. In recent years, local internet ecosystem has fired-up the internet purchases with
the wide adoption of digital payment solutions.

The online gaming market, characterized by large volumes, is rising fast in terms usage and
monetisation which is majorly driven by Internet reaching every corner of the country, rising
disposable income, increase in smartphone penetration, young India, rise in digital payment,
affordable new technologies, growing local developer ecosystem, localized games etc.

2. Online Ecosystem (Gaming)

Online Ecosystem includes everything being available on internet, playing game, watching
others play video games via e-sports, streaming or video-sharing platforms, which typically
provide options for viewers to comment on or interact and other members of the audience.
‘Online Gaming’ facilitate procurement or game-play or accessed through online channels
which requires internet for the primary game-play experience or monetisation. Online games
include all genres and can be played across single-player, multiplayer/ multiplayer formats.

Children are a key consumer group for online gaming, which can offer opportunities to
collaborate, learn and simply have fun. An average Indian online gamer is a below 24-year
male and is introduced to online gaming through their friends, family and peer group and is
engaged in gaming for stress relief and social interaction. Some survey data
Based on the internet usage, the finding data can be divided as per casual gamer and heavy
gamer that engages in gaming over a wide range of genres. The consumption pattern between
of Casual and heavy gamers vary in terms of gender distribution, online spends, data
consumption, daily spend time on internet/games etc.
Popular online activities present both risks and opportunities for children. Risks that online
gaming ecosystem may pose to child rights mirrors other aspects of children’s online
participation too. These range from the collection and monetization of children’s data to
cyberbullying, hate speech and exposure to other inappropriate conduct or content. Best
approach must be determined to policymaking, advocacy and industry initiatives, careful
consideration must be taken to balance risks and opportunities presented by online gaming
vis-à-vis children’s rights. When it comes to online gaming, it is important to understand how
online gaming impacts children’s well-being in the long term, how the influence of online
gaming compares to other factors such as their family situation, friendships, school
environment, community safety and a range of social inequalities, including gender
inequality, children’s right to play, participate and express themselves, while protecting them
from discrimination and abuse, or violations of their right to privacy and freedom from
economic exploitation.

3. Online Spend (Time & Money)

Average time spend on online games in India as on March 2020

Children spend more of their time playing online games, there are concerns over how this
activity might have negative impacts on physical exercise, real-life social interaction or other
activities important to children’s health and well-being. Playing online games with friends
after school does not pose issues from a health perspective. However, due to the immersive
qualities of online games and the incipient expansion of virtual reality games, children may
need additional support to find a healthy balance between gaming and other activities.

The online gaming market have been blooming year on year and had seen a steep rise in the
number of user along with the paid subscription of games including in-app purchases.
 4. Online gaming – The Risks
Gaming is a fun and sociable way to spend time, encouraging teamwork and developing skills.
With all good stuff, there are a few risks that might impact the wellbeing. Games can offer
young people a sense of escape from the reality of the world and the social aspect of some
games can help children feel part of a community. However, without the right guidance on
what games to play or when to play, children can be exposed to certain risks such as in-game
bullying, online grooming or in some extreme cases gaming addiction.

World Health Organization (WHO) has recently included unhealthy engagement in gaming in
the International Classification of Diseases as a ‘Gaming Disorder’, a classification intended to
support those who suffer severe life impairments as a result of their gaming habits. It is
defined as a pattern of gaming behaviour characterized by impaired control over gaming,
increasing priority given to gaming over other activities to the extent that gaming takes
precedence over other interests and daily activities. The behaviour pattern must be of
sufficient severity to result in significant impairment in personal, family, social, educational,
occupational or other important areas of functioning and would normally have been evident
for at least 12 months. Studies had already suggested situations in which someone spends
hours sitting in one place can increase the risk of a Deep Vein Thrombosis (DVT).

Bright flashing lights are another area for concern which are often part of online/video game
experiences. Current research shows that video games don’t cause epilepsy but can trigger a
seizure in the extremely small number of people, who already have Photosensitive Epilepsy.

Online interactions which is much more fun when played with other people, which has risen
the concerns. Players do not necessarily know who they are playing with and the overlap of
online social sharing sites and online games had created more risks for children. One needs
to tread with caution because children who play games and identify as gamers may feel
increasingly stigmatized or ostracized by their parents, schools or communities as a result –
and be falsely seen as suffering from a mental disorder.
Online video games require relatively complex hardware to participate in, along with a high-
speed internet connection. This can create the perception that you need the most up to date
technology which can be costly affair for many. Although with digital payment via mobile
there are a wide range of ways that your child can pay and play video games online without
breaking the bank. There are other costs that parents should be aware of those that crop up
after the initial purchase or download of the game. An increasingly popular way to fund game
development is to offer games for free but then charge for content or characters in the game,
called as freemium games. For example – Fortnite is making a lot money from it’s in-game
purchases that unlock new outfits and dances.

In some instances, these transactions (sometimes called Loot Boxes) offer a chance to win an
in-game item of varying value to the player. This can appear similar to gambling as there is
luck involved as to which item the player will get. Since there is no monetary value, this is
actually not considered as gambling. Children, who want more in-game currency to purchase
loot boxes, are sometimes targeted but unofficial third-party apps offering this in exchange
for information. Online gaming usually refers to gambling websites where players can partake
in traditional gambling games of cards, dice and slot machines.
Few of the online risks, quickly iterated as Cyberbullying, Inappropriate content, Sexting, Self-
harm, Screen time, Radicalisation, Online grooming, Online pornography, Online reputation,
Privacy and identity theft

5. Online gaming – The Advice

5.1. Online Game addiction
• Review regularly, what they are playing and for how long
• Apply time limits using inbuilt tools or parenting control mechanisms
• Encourage them to take breaks, perform body movements, play outdoor for the
similar time to online game plays.
• Seek support from Grand Parents, elders etc. if necessary.

5.2. Contact with Strangers

• Parents and caretakers, need to understand the games the child is playing and learn
how to set them up safely.
• Check settings on devices
• Keep devices in shared family spaces
• Play sound on speakers not headset
• Turn on notifications on your account
• Set up children's accounts
• Play together
• Use settings to create groups of real friends to play with

5.3. Online Gaming Health

• Review child's gaming diet
• Be aware of Photosensitive Epilepsy
• Play active games together
• Symptoms to watch out for, if any found/learnt/observed
• Advise regular breaks – children play games just on screens, it is good advice to ensure
they take breaks every hour. Not only will this keep them moving but it offers a chance
for a change of activity.

5.4. Online Game Costs and Gambling

• Review ongoing gaming costs
• Use parental controls
• Set up email on device to flag purchases
• Use gift cards to make purchases rather than credit cards
• Children, who want more in-game currency to purchase loot boxes, are sometimes
targeted but unofficial third-party apps offering this in exchange for information. It’s
important that parents understand this, educate children, and ensure appropriate
passwords are set on credit card details. Some countries, such as Belgium have
outlawed the use of “loot boxes” in games because they are seen as gambling aimed
at children. In UK and US, games are now labelled as having In-App purchases as part
of the rating system.
5.5. General
• Tell them that they are allowed to play online as long as they stick to your rules
• Make it a habit to play together, especially if your child is young
• For young children, make it policy that they can only play with people you both know
• Turn off voice chat for multiplayer games like Overwatch and Destiny
• Schedule time to talk about their MMO guild and their guild-mates
• Talk about inappropriate, harmful language and demonstrate good behaviour
• Show your child how to report toxic behaviour in their favourite games
• Talk to your child about online predators
• Discuss risky behaviour & spell out what a risky relationship is
• Talk about the dangers of chat rooms
• Warn your child about online flirting
• Discourage bring up sexy selfies – Kids should be warned and shall never take images
of themselves that they wouldn’t want to be seen by all of their classmates & teachers
• Follow the family rules, and those set by the Internet service provider
• Never post or trade personal pictures
• Never reveal personal information, such as address, phone number, or school name
or location
• Use only a screen name and don't share passwords (other than with parents)
• Never agree to get together in person with anyone met online without parent
approval and/or supervision
• Never respond to an unknown or threatening email, message, post, or text
• Always tell a parent or other trusted adult about any communication or conversation
that was scary or hurtful
• Consider surveillance software & keep the computer in a common area where it’s use
can be watched and monitor, not in individual bedrooms
• Bookmark kids' favourite sites for easy access
• Check your credit card and phone bills for unfamiliar account charges
• Take your child seriously if he or she reports an uncomfortable online exchange
• Tell your child that he/she can always talk to you

6. Discussion & Decision

6.1. Gaming Time & Health Concerns
• Industry shall support parents and guardians to set fair rules and boundaries together
for the children healthy gameplay?
o Governments have a role to play to encourage offline activities for children to
support a healthy balance?
• Game (platform) design shall support children to learn how to manage their gaming
time, encourage healthy playing habits (e.g. by encouraging breaks)?
• Features in games that are deliberately designed to ‘hook’ players and which children
might find harder to resist shall be discouraged?
o Governments may regulate to ban or restrict game features that might lead to
excessive use by children?
• Some prerequisites/guidelines from government to restrict children’s access or time
of play, in addition to solid, independent and high-quality research and evidence?
• How can the privacy concerns relating to legislation that requires children to be
identified or authenticated with their real names be addressed?
• Is there a contradiction between encouraging the growth of the e-sports industry and
professional gamers – some of whom will be children – and the discourse around
excessive gameplay?
• What new health and developmental issues will virtual-reality-based games pose to
children?
• Have these been sufficiently explored and understood to market VR-games to
children?

6.2. Participation & Protection from Abuse & averting toxic environments
• Companies shall make conscious efforts to introduce diverse characters (including
lead characters) and avoiding stereotypical representations or gender roles for the
game characters? Is there a conscious effort to make games appealing to both girls
and boys? How can this be mainstreamed into game design?
• Efforts shall be made in hiring, promotions and inclusive workplace policies to ensure
companies’ workforce reflects and understands the needs and desires of its diverse
customer base?
• Streaming services shall best enforce their community standards and actively weed
out racist and sexist language and sexually explicit content? Flagging and reporting
mechanisms shall be encouraged to bring in place?
• Companies shall encourage popular streamers to openly speak out against racism,
sexism, hate speech and other forms of bullying, and promote diverse role models to
set a healthy precedent for children and young adults?
• e-sport tournament hosts, sponsors and teams shall tackle toxic behaviour by e-sport
professionals, including commentators, players and other representatives of
organizations and promote positive gender behaviours and greater social and gender
inclusion? Who has the primary responsibility?

6.3. Age limits, Verification, and Ratings

• Age limits shall effectively be implemented to protect children without preventing
their right to play and participation?
• Age limits shall also be applied to games and also to streaming services that broadcast
the same games
• Given that children will access content regardless of the age limit, what are companies
doing to ensure that the content they access is suitable for children?
• Should age limits be more strongly enforced or even made legally binding?
• Is there room for further innovation around age verification and enforcement of age
limits of terms of service? Should industry-wide solutions/ratings be sought or are the
gaming companies best placed to find solutions for their specific environments?
• What are the challenges preventing app stores and other online distributors to
conform their age limits to those set by rating agencies?
 • Are current mechanisms for monitoring potentially illegal activity during in-game
communication effective? What privacy concerns might occur with different
monitoring mechanisms?

6.4. General
• Government shall encourage the conduct of awareness campaigns in relation to
Online usage for parents. This shall include all the advises in this note and beyond with
the practical implementation of control mechanism.
• Government shall enforce the conduct of awareness campaigns in school & colleges
for all the advises in this note and beyond for Do’s & Don’ts of Online ecosystem.
• Government shall establish a regulatory body/helpline with the qualified & technical
manpower to provided support and guidance to parents, citizens, escalate any wrong
online doings, issue advisories etc.

7. The Online Game – Free Fire

Garena Free Fire, also known as Free Fire, is a battle royale game, developed by 111 Dots
Studio and published by Garena for Android and iOS. It became the most downloaded mobile
game globally in 2019. The game received the award for the "Best Popular Vote Game" by the
Google Play Store in 2019. As of May 2020, Free Fire has set a record with over 80 million
daily active users globally and as of November 2019, Free Fire has grossed over $1 billion
worldwide.

Garena is a Singaporean online game developer and publisher of free games. The company
distributes game titles on Garena+ in various countries across Southeast and East Asia,
including the multiplayer online battle arena (MOBA) games. In 2019, Garena announced
plans to reorganize its various interests as a conglomerate under Sea Limited. Garena is now
one of Sea Limited's subsidiaries (such as e-commerce company Shopee) and continues to be
the umbrella company for Sea Limited's gaming interests.

Sea Limited is a Singaporean multinational technology conglomerate. Established in 2019, Sea

Limited is a holding company for various subsidiaries including Shopee, SeaMoney, Garena
and Lion City Sailors FC, a football club which plays in the Singapore Premier League (SPL). As
of 2021, it has over 33,000 employees.

The online gaming ecosystem is crowded with such games having in app purchases, loot
boxes, paid subscription, ad based revenues etc. One shall not be imperative in restricting on
a single game in a crowded arena, although the advises suggested above shall be well
communicated to children and parents by awareness campaigns, guidelines, counselling etc.
It is also required to take discussion pointers on a relevant platform to be address by the
government to regulate all games which are venerable & sensitive till teenage (atleast).

8. References
• World Health Organization, ‘ICD-11 for Mortality and Morbidity Statistics: 6C51 Gaming disorder’, WHO, 2018,
https://icd.who.int/browse11/l-m/en#/http://id.who.int/icd/entity/1448597234
• Burt, Chris, ‘Tencent Trials Facial Recognition to Combat Video Game Addiction in Minors’, Biometric Update.com, 5 October
2018,www.biometricupdate.com/201810/tencent-trials-facial-recognition-to-combat-video-game-addiction-in-minors
• “Statement to the 69th Session of the UN General Assembly.” OHCHR | Freedom of Religion: UN Expert Hails Albania, but Notes
New Challenges & Unresolved Issues from the Past, 23 Oct. 2014,
www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=15220&LangID=E
• Cote, Amanda C., ‘“I Can Defend Myself”: Women’s strategies for coping with harassment while gaming online’, Games and
Culture’,vol. 12, no. 2, 24 May 2015, pp. 136–155.
• Twitch, ‘Terms of Service’, Twitch Interactive Inc., 2017, www.twitch.tv/p/legal/terms-of-service
• International Age Rating Coalition, www.globalratings.com
• Pan European Game Information, ‘PEGI Online’, https://pegi.info/page/pegi-age-ratings
• VSC Rating Board, ‘Who We Are’, St. Albans, UK, 2018, https://videostandards.org.uk/RatingBoard
• Hilgert, Felix, and Philipp Sümmermann, ‘Video Game Age Ratings in Europe (Part 1 of 3: The Basics)’, VideoGames.Law, 24 March
2016, http://gameslaw.org/video-game-age-ratings-in-europe-part-1-of-3-the-basics
• https://www.internetmatters.org/resources/online-gaming-advice/online-gaming-the-risks/
• https://www.understood.org/articles/en/9-ways-to-protect-your-child-from-online-predators
• https://superparent.com/article/8/8-ways-to-keep-your-kids-safe-in-online-games
• https://kidshealth.org/en/parents/net-safety.html
• https://assets.kpmg/content/dam/kpmg/in/pdf/2017/05/online-gaming.pdf
• https://images.assettype.com/afaqs/2021-06/1ef54dc8-61db-410d-893e-
957ce23e0103/Beyond_the_tipping_point__A_primer_on_online_casual_gaming_in_India_low_size.pdf
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September 2017. https://gamek.vn/free-fire-them-mot-playerunknowns-battlegrounds-made-in-vietnam-nua-tren-mobile-
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• https://www.garena.sg/
• "Garena's battle royale game Free Fire surpasses $1 billion of lifetime revenue".
https://www.pocketgamer.biz/asia/news/72010/garena-battle-royale-free-fire-1-billion-dollars/
• Wasif, Ahmed (17 December 2019). "Free Fire beats PUBG Mobile to become the most downloaded mobile game of 2019". Dot
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• Takahashi, Dean (18 May 2020). "Free Fire sets record with 80 million daily players for free-to-play mobile battle royale".
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• Free Fire India official twitter account. https://twitter.com/indiafreefire?lang=en