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I haven't had a look at the original text from China, but wondering how much they accounted for. Any of these rules could be easily circumvented if they didn't account for multiple scenarios.
"We don't have a reward for spending money for the first time, but everyone does have a digital coupon for $5 off of their first $10 purchase when they make an account."
"The players don't get any extras when they buy more of our digital currency, but every gacha pull does make the next 5 pulls a bit cheaper."
"No, we're not giving rewards for daily log-ins, but players can buy this bonus that adds a gift-giving NPC to the main town for 30 days, who will trade a small parcel of premium currency for a single gold coin once per day."
I guess we just shouldn't make any law about anything since people can go "well akshually" about it. /s
That's not what I'm saying. I was just hoping this law has teeth, because companies who are greedy for money will always try to circumvent whatever new restrictions are sent their way.
I'm thinking back to earlier policies set by China like the restrictions against showing undead/human remains in video games. World of Warcraft set up all these euphemistic workarounds to circumvent the law while realistically changing as little as possible, basically defeating the purpose of it.
China outlawed loot boxes, but then season passes and gatcha models were implemented in short order to continue exploiting consumers. If the law doesn't account for all sorts of scenarios that can be abused, it's just going to be a game of cat and mouse.
The only one I'm aware of is China's cultural distaste for showing bones, so Blizzard had to hide the skeletal structure in the Undead player class. In other words, it wasn't about the undead, it was only about showing bones.
What else did they do?
Well, it's China. How the commerce law affect you will depend heavily on who you know in the government and the party. If the new law is heavily pushed by someone important, they probably won't turn a blind eye for minor technicality. Someone up high probably got mad with their kids getting addicted with microtransactions and want to neuter it. Once that person lost interest or no longer in power, the enforcement will probably become much lenient.
This is China, their CEO will misteriously disappear if they try something so obvious.
How do Chinese judges react to transparent attempts to circumvent laws that have the same effect as just breaking the law? I wouldn't expect them to fall for the "I'm not touching you" defense.