1

EXAMPLES OF COMPLETE

GACHA

1. Purpose

These Examples are provided to assist social game platform operators in completely

prohibiting so-called Complete Gacha (“Comp Gacha”) elements in social games and

similar applications (“Social Games”) on their platforms in Japan and, further, to alert

other businesses by showing noteworthy examples to which they should pay attention

(even if they may not strictly speaking be considered Comp Gacha) so that users can

make informed decisions, thereby creating a positive environment in which they can

more safely enjoy playing Social Games.

Please note that the examples described herein do not cover all possible cases that will

be considered as “card matching”, which is banned by the Japanese Act Against

Unjustifiable Premiums and Misleading Representations (the “Act”), nor do they

determine what will or will not be considered as banned “card matching”. Since these

examples do not provide any legal opinions or interpretations, it is recommended that

Social Games should be planned, developed, and provided to users after an

appropriate authority, attorney, or other expert is consulted for advice on a

case-by-case basis.

These Examples may be supplemented or amended as necessary (e.g., amendment of

laws and regulations, change of an appropriate authority’s opinion).

2. Definitions

In these Examples, the following terms shall mean as follows. If not defined herein, the

terms shall have the same meaning as defined in the “Complete Gacha Guidelines”.

2

(1) “Platform Operators” mean operators of platforms on which any Social Games

(whether such games are developed or operated by the operators themselves

or by Social Game Providers) are provided to users.

(2) “Social Game Providers” mean operators that provide Social Games through

platforms.

(3) “Gacha” means a feature of a game with which a user can obtain virtual

characters and items used in the game (“ Virtual Items”) randomly, and not

through the user’s direct choice.

(4) “Gacha Items” means Virtual Items that can be obtained by users through

Gacha.

(5) “Paid Gacha” means a form of Gacha in which users can obtain Gacha Items in

exchange for real money or virtual currency, or through the purchase of

products or services for real money.

(6) “Paid Gacha Items” mean Gacha Items that can be obtained through Paid

Gacha. Where Gacha Items can be obtained through both Paid Gacha and

any other way, such Gacha Items shall be considered as Paid Gacha Items.

(7) “Random Item Charge” means a type of charge for providing Virtual Items

randomly and not through the user’s direct choice (e.g., providing Virtual Items

randomly after unlocking and opening treasure boxes with keys that users can

purchase for real money or virtual currency).

(8) “Item Rarity” means one or more designated groupings assigned to items used

in Social Games to show how rare the items are.

(9) “Paid Items” mean Virtual Items that are obtained by users through their own

direct choice in exchange for payment (i.e., items that are not obtained

randomly).

3

3. What Would be Considered as Comp Gacha?

The following examples would be considered as Comp Gacha.

(1) Example 1: Typical Comp Gacha

A case where users are clearly shown a pre-determined combination of two or more

different Virtual Items that can be obtained through Random Item Charge such as Paid

Gacha as a condition to getting another Virtual Item.

Z

Another Virtual Item

A

B

C

D

E

Virtual Items

Pa

id G

acha

4

(2) Example 2: Typical Comp Gacha with Bonus Event being Required for Completion

A case where users are clearly shown a pre-determined combination of two or more

different Virtual Items that can be obtained through a Random Item Charge, such as

Paid Gacha, as a condition to participation in a bonus "event” within a game (e.g., fight

with bosses and access to bonus worlds), with the conditions necessary to complete the

event clearly shown.

This example would be considered as Comp Gacha since it is essentially the same as

Example 1 above; in other words, merely adding such an event does not circumvent the

Act, which prohibits “card matching”.

Z

Another Virtual Item

A

B

C

D

E

Virtual Items

Pa

id G

acha

Event

5

(3) Example 3: Bingo Gacha (Comp Gacha with Pre-Determined Combination Patterns)

A case where users are clearly shown a pre-determined pattern of combinations of two

or more different Virtual Items that can be obtained through a Random Item Charge

such as Paid Gacha (e.g., a Bingo pattern, as shown below, of completing a line with 5

Virtual Items in a vertical, horizontal, or diagonal row on a 5 x 5 grid) as a condition to

getting another Virtual Item.

This example would be considered as Comp Gacha since, although it is not clearly

shown to users, each such combination will be ascertainable from the pattern.

Z

A

F

K

P

U

B

G

L

Q

V

C

H

M

R

W

D

I

N

S

X

E

J

O

T

Y

Grid of Virtual Items

Another Virtual Item P

aid

Ga

cha

6

(4) Example 4: Comp Gacha Providing Rewards, not Premium Virtual Items

A case where users are clearly shown a pre-determined combination of two or more

different Virtual Items that can be obtained through a Random Item Charge such as

Paid Gacha as a condition to getting rewards (e.g., enhancing various parameters of the

Virtual Items).

A

B

C

D

E

A

B

C

D

E

Pa

id G

acha

Virtual Items

Rewards such as

enhancing various

parameters

7

(5) Example 5: Comp Gacha with “Fusion”

A case where users are clearly shown a pre-determined combination of two or more

different Virtual Items that can be obtained through a Random Item Charge such as

Paid Gacha as a condition to getting another Virtual Item; however, in contrast to the

typical Comp Gacha described in Example 1, all or some of these collected Virtual

Items will disappear upon successful completion (this feature will be called

“Fusion”).

Note:

If Fusion is built in a game as one of its basic functions and can be used for any

combination of Virtual Items, it will not come under this example since the

combination is not pre-determined. Still, even if the combination is not

pre-determined, it is recommended that Fusion not be used for any combination of

three or more different Virtual Items.

Z

A

B

C

D

E

A

B

C

D

E

Virtual Items

Fusion

The original

Items will

disappear.

Pa

id G

acha

Another Virtual Item

8

4. Examples to Which Platform Operators should Pay Particular Attention

Platform Operators should review the following examples to consider whether similar

features should be adopted in Social Games on their platforms and if so, how such

features should be adopted, so that users can make informed decisions on whether

they should use such features as part of their play.

(1) Example 6: Collecting a Certain Number of the Same Items to Achieve Completion

A case where users are clearly shown the collection of a certain number (two or more)

of a pre-determined Virtual Item that can be obtained through a Random Item Charge

such as Paid Gacha, as a condition to getting another Virtual Item.

This example includes where users are clearly shown that the collection of a certain

number (two or more) of any one of predetermined Virtual Items or a certain number

(two or more) of any one of Virtual Items within a pre-determined Item Rarity is a

condition to getting another Virtual Item.

Please note, however, that this example does not include situations where users are

clearly shown that the collection of a certain number (two or more) of any Virtual Item is

a condition to getting another Virtual Item.

Z

Another Virtual Item

A

A

A

A

A

Virtual Items

Pa

id G

acha

9

(2) Example 7: Adding an Event After Completion

A case where users are clearly shown the collection of a certain number (two or more)

of a pre-determined Virtual Item that can be obtained through a Random Item Charge

such as Paid Gacha as a condition to participation in a bonus “event” within a game

(e.g., fight with bosses and access to bonus worlds) with the conditions necessary to

complete the event clearly shown.

Z

Another Virtual Item

A

A

A

A

A

Virtual Items P

aid

Ga

cha

Event

10

(3) Example 8: Fusion

A case where users are clearly shown the collection of a certain number (two or more)

of a pre-determined Virtual Item that can be obtained through a Random Item Charge

such as Paid Gacha as a condition to Fusion; however, in contrast to Example 6, all or

some of these collected Virtual Items will disappear upon successful completion.

This example does not include situations where Fusion is built in a game as one of its

basic functions and can be used for any Virtual Item, since such Virtual Item is not

pre-determined.

Z

A

A

A

A

A

A

A

A

A

A

Virtual Items

Fusion

The original Items

will disappear.

Pa

id G

acha

Another Virtual Item

11

This example will include the following situations, as long as the Virtual Items to be

collected are pre-determined. However, situations where Fusion is built in a

game as one of its basic functions and can be used for any Virtual Item will fall

outside this example.

Fusion

A

A

A

A

Fusion

C

B

B

Fusion

Fusion

A

A

A

A

C

B

Fusion

D Fusion

Pa

id G

acha

Pa

id G

acha

12

(4) Example 9: Collecting Points

This example involves situations where a certain number of points is assigned to a

Virtual Item and users reach a certain number of points by collecting Virtual Items with

points assigned, after which the users receive another Virtual Item depending on the

points users collect (this includes where the amount of points assigned will be

determined randomly, e.g., with dice).

Z

A

B

C

D

E

1 point

2 points

4 points

5 points

3 points

Pa

id G

acha

Points

30

points

Another Virtual Item

Virtual Item

13

(5) Example 10: Rarer Items or Guaranteed Better Odds

If users get a pre-determined Virtual Item or any Virtual Item within a pre-determined

Item Rarity through a Random Item Charge such as Paid Gacha, the users are

guaranteed to get a rarer Virtual Item or to have better odds of getting a rarer Virtual

Item (the time period of such guarantees may be limited).

B A C

Pa

id G

acha

If Item A

appears, odds

will change

thereafter.

Rarer Item or

higher odds

guaranteed

Rarer Item or

higher odds

guaranteed