First let's lay out some facts...
One Page Summary of the Protecting Children Abusive games Act which cites...
Title 16: Commercial Practices, PART 312—CHILDREN'S ONLINE PRIVACY PROTECTION RULE
This would be determined by subject matter, visual content, and other indicators similar to those used to determine applicability of the Children’s Online Privacy Protection Act (COPPA)
How does COPPA work? Information persons under the age of 13 is broadly off limits for internet companies. That's clearly defined. There's no judgement factor in regards to content.
What I'm trying to get at here is how do they qualify "subject matter, visual content, and other indictators?" These things are broadly protected under the 1st amendment. This is not generally a decision the government has the right to make anyway. All government can do is advise (e.g. require appropriate labeling of TV shows and films indicating what age is generally considered appropriate for the content). It can't generally impose restrictions on access to said content that a parent or guardian doesn't enable.
If the goal is to prevent kids from getting access to gambling-like mechanisms, this is a pretty terrible way to go about it...
Games with wider audiences whose developers knowingly allow minor players to engage in microtransactions
Microtransactions require payment, payment usually links to a credit card, and there are major restrictions in regards to having a credit card. In other words, this statement is pointless.
Reading the rest of the "one pager," it's just as ridiculous...
The solution is two fold and simple:
1) Categorize "microtransactions" and "pay-to-win" as gambling so all gambling laws apply. If a child gets swindled into these gambling systems, they can't be held accountable for whatever alleged fees they incurred because, like any casino, they should have been shown the door and not allowed to participate. Games simply have to be designed to allow digital purchases to be rescinded/forfeited (parent tells game publisher these were unauthorized by a child, they refund the money and take everything purchased off the account). Put a 60 day limit on this so it extends into/past credit card grace periods/due dates.
2) Throw ESRB to the curb and extend the ratings system created by the FTC to video games to inform buyers in a reasonable way. ESRB profits by keeping these manipulative practices in shadow. There's also nothing to compel any game from getting ESRB rated other than to be sold on consoles by Microsoft, Sony, and Nintendo. FTC could compel video games to be rated before they can go on sale in the USA so there isn't holes in rating.
If your intent was to be antagonistic, bravo!
