Advertising under scrutiny: How LC International fell short of ASA standards

Introduction

The Advertising Standards Agency (“ASA”) has upheld two complaints made against Ladbrokes related to TV and video on demand (“VOD”) advertisements promoting  its “Ladbucks” rewards programme (the “ads”). The ads promoted the betting platform of LC International Ltd (trading as “Ladbrokes”) by outlining that users could collect “Ladbucks” when playing certain games on the betting platform which could be redeemed and used for free bets and spins. The ASA ultimately deemed that the ads, and the name “Ladbucks”, were likely to strongly appeal to under-18s, and as such, were in breach of advertising rules.

Background

The TV ad was seen on 17 December 2024, promoting “Ladbucks” as a new way to be rewarded when using certain betting functions on Ladbrokes. The “Ladbucks” were displayed as stylised coins featuring the initials ‘Lb’ and could be redeemed for free bets/spins on certain games. The VOD ad was seen on Channel 4 on demand on 23 December 2024, featuring the same content.

The complaints were raised by two viewers who believed the name of the product was likely to be of strong appeal to those under 18 years of age, and as such, were in breach of the BCAP Code (in respect of the first ad) and the CAP Code (in respect of the second ad).

The issue at the centre of the matter was the term “Ladbucks” and its potential similarity to other game coins from videogames popular with under-18s, specifically ‘V-bucks’ from Fortnite and ‘Robux’ from Roblox.

Decision

The ASA upheld the complaint, outlining that the term “Ladbucks” was likely to be of strong appeal to under-18s. The ASA relied upon Ofcom’s 2024 report into media use which stated that 89% of 11-18 year olds played video games online weekly with both Roblox and Fortnite being the types of games frequently played by this demographic. The ASA also cited the Academy of Animated Arts which showed Fortnite had the most combined Youtube and Twitch weekly viewing hours of any game. Ladbrokes argued that “Ladbucks” were not associated with any in-game currencies as such currencies had to be purchased to buy in-game items, making them a separate type of product. Nevertheless, the ASA determined that under-18s were likely to be familiar with the games and the reward schemes, including the in-game currencies.

Furthermore, the ASA determined that the electronic design of “Ladbucks” had a strong resemblance to the design V-bucks and previous design of Robux. All of which were circular in shape, resembling a poker chip, with their respective initials displayed in the middle. The ASA determined that it was not necessarily the imagery resembling a poker chip that was particularly appealing, but when used in conjunction with the term “Ladbucks”, it was likely to have been recognisable and perceived to be similar to the Robux and V-bucks currencies by under-18s.

Finally, the actual term itself was determined to have been recognisable and of appeal to some under-18s. Ladbrokes argued that ‘bucks’ was a colloquialised term for dollars and was often used to refer to money or dollars and had no origins in youth culture. Furthermore, Ladbrokes stated the term ‘lad’ referred to a boy or young man and they were simply using their brand name which had never been used in the colloquial context. As such, they believed the term “Ladbucks” had no inherent strong appeal to under-18s. However, the ASA determined that in the context of the names of the other gaming currencies, there were strong similarities, especially given all three currency names used the same stylistic method where the prefixes (‘Lad’, ‘V’ and ‘Ro’) represented the respective brands’ form of currency (V-buck is a shortened version of Vindertech buck, a fictional company in Fortnite). Finally, although the ASA accepted that the use of the term ‘lad’ was in relation to the brand name, when combined with ‘bucks’ the ASA determined that it would be recognisable and of appeal to some under-18s.

Therefore, the ASA deemed Ladbrokes breached the following rules:

1. BCAP Code rule 17.4.5 - Advertisements for gambling must not be likely to be of particular appeal to under-18s;
2. CAP Code rule 16.1 - Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited; and
3. CAP Code rule 16.3.12 – Marketing communications must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture.

Comment

The ASA’s decision is another reminder of the strict approach that is taken in regard to gambling advertisements in the context of under-18s (see here another recent example). The decision reinforces a zero-tolerance stance in the context of gambling advertising and its appeal to under-18s.

As discussed, there were clear similarities between “Ladbucks” and other similar in-game currencies in terms of the naming conventions, however, in the circumstances of how they operated and the context in which they are used there are clear differences. Nevertheless, the decision suggests that branding strategies must consider youth associations, not solely intent or the targeted audience. Due care must be given to the design of these products along with brand-related puns in order to avoid inadvertently having comparisons drawn with products that are targeted for under-18s.

Co-authored by James Head, Solicitor Apprentice