read the article on Video Games. Highlight or keep tract of any information that you find convincing for the "Yes" side of the article and the "No" side. Then, in the Persuasive Chartthere are 8 boxes. Please include four pieces of information from each side article that you found the most convincing. Therefore, by the time you are finished you will have 8 pieces of information that you thought were the most persuasive (4 from the "Yes" side and 4 from the "No" side).

YES . Steven F. Gruel Brief of Amicus Curiae in Case of Brown v. Entertainment Merchants Association I. Science Confirms That Violent Video Games Are Harmful to Minors Allowing the State Clear Justification in Regulating Children's Access to These Materials 1. A Minor's Exposure to Violent Video GamesMore Time Spent Playing Games With Increasing Graphic Violence A minor's exposure to the avalance of violent video games is staggering. Video games first emerged in the 1970s, but it was during the 1990s that violent games truly came of age. In 1992, Wolifenstein 3D, the first major \"first-person shooter\" game was released. In a first-person shooter, one \"sees\" the video game world through the eyes of the player, rather than seeing it as if looking on from afar. The player is the one fighting, killing, and being killed. Video game historian Steven Kent noted that \"part of Wolfenstein 3D popularity sprang from its shock value. In Wolfenstein 3D, enemies fell and bled on the floor.\" With ever changing advancements in technology, the dramatic increases in speed and graphic capability have resulted in more realistic violence. As an example, in the video game Soldier of Fortune, the player/shooter can wound an enemy causing exposed bone and sinew. As the video games became more graphically violent, the average time children played these games continued to climb. In the book, Violent Video Game Effects on Chil- dren and Adolescents, the authors note that in the early 1990s, boys averaged 4 hours a week and girls 2 hours a week playing video games, In a few years these averages jumped to 7.1 and 4.5, respectively. In a recent survey of over 600 eighth and ninth-grade students, children aver- aged 9 hours per week with boys averaging 13 hours per week and girls averaging 5 hours per week. U.5. Supreme Court, No. 08-1448, 2010. In 1993, United States Senators Joseph Lieberman and Herbert Kohl noticed the increasing violence in video games and held hearings to examine the issue. Although there was much less research on the effects of violent video games, the senators put pressure on the video game indus- ry to create a rating system, The goal of the rating system was to provide information to parents about the content of games so that they could make informed decisions about which games their children could play. However, these industry \"voluntary\" labels rating video games are inherently flawed and have failed due to \"invalid assump- tions about what is safe versus harmful.\" In 2003, more than 239 million computer and video games were sold in the United States; that is almost two games for every household in the United States. More than 909% of all U.S. children and adolescents play video games. The National Youth Violence Prevention Resource Center has stated that a 2001 review of the 70 top-selling video games found 49% contained serious violence. In 41% of the games, violence was necessary for the protagonists to achieve their goals. There is no doubt, violent video games are among the most popular entertainment products for teens and adolescents, especially for boys. New generation violent video games contain sub- stantial amounts of increasingly realistic portrayals of vio- lence. Elaborate content analyses revealed that the favored natrative is a \"human perpetrator engaging in repeated acts of justified violence involving weapons that results in some bloodshed to the victim.\" 2. Scientific Studies Confirm that Violent Video Games Have Harmful Effects Minors In a nutshell, teens and adolescents play video games fre- quently, and a significant portion of the games contain increasingly realistic portrayals of violence. Viewing vio- lence increases aggression and greater exposure to media violence is strongly linked to increases in aggression. - 136 ir Taking Sides: Psychological Issues Playing a lot of violent games is unlikely to turn a normal youth with zero, one or even two other risk factors into a killer. But regardless of how many other risk factors are present in a youth''s life, playing a lot of violent games is likely to increase the frequency and tbe seriousness of his or her physical aggression, both in the short term and over time as the youth grows up. These long-term effects are a consequence of powerful observational learning and desensitization processes that neuroscientists and psychologists now understand to occur automatically in the human child. Simply stated, \"adolescents who expose themselves to greater amounts of video game violence were more hostile, reported get- ting into arguments with teachers more frequently, were more likely to be involved in physical fights, and per- formed more poorly in school. In a recent book, researchers once again concluded that the \"active participation\" in all aspects of violence: decision-making and carrying out the violent act, result in a greater effect from violent video games than a \\.wlolex_'nt movie. Unlike a passive observer in movie watching, in first-person shooter and third-person shooter games, you're the one who decides whether to pull the trigger or not and whether to kill or not. After conducting three very different kinds of studies (experimental, a Cross- sectional correlational study, and a longitudinal study) the results confirmed that violent games contribute to violent 'behavior. The relationship between media violence and real- life aggression is nearly as strong as the impact of ciga- rette smoking and lung cancer: not everyone vsrho smokes will get lung cancer, and not everyone who views media violence will become aggressive themselves. However, the connection is significant. ) In an upcoming publication concerning children and violent video games, three complementary theo- retical perspectives are discussed when contemplating the effects of playing video games. The General Aggres- sion Model and its offshoot the General Learning Model describe the basic learning processes and effects involved in both short-term and long-term effects of playing vari- ous types of games. The Five Dimensions of Video G_ame Effects perspective describes different aspects of video games and video game play that influence the specific effects likely to occur. The Risk and Resilience perspec- tive describes the effects of video game playprosocial, antisocial, and othertake place within a complex set of social and biological factors, each of which contbn{te[s] to development of the individual's thoughts, feelings, and behaviors. The main findings can be succinctly summarized: playing violent video games causes an increase in t.he likelihood of physically aggressive behavior, aggressive thinking, aggressive affect, physiological arousal, and desensitization/low empathy. It also decreases helpful or prosocial behavior. With the exception of physiological arousal (for which there are no cross-sectional or longi- tudinal studies), all of the outcome variables showed d{e same effects in experimental, cross-sectional, and longi- tudinal studies. The main effects occurred for both ma%es and females, for participants from low-violence co]lec:tlv- istic type Eastern countries (e.g., Japan), and from high- violence individualistic type Western countries (e.g, USA, Europe). pl?eseatch also indicates that the aggression carried out by video game characters is usually portrayed as jus- tified, retributional, necessary to complete the game, rewarded and followed by unrealistic consequences. The overall level and realism of violent depictions, use of guns and likelihood of being killed by a gun has risen substa_n tially over time; additionally, female victims and police officer victims rose significantly across time. Many researchers have begun studying the concept of video game \"addiction\" and most researchers study- ing the pathological use of computer or video games have defined it similarly to how pathological gambling is definedbased on damage to family, social, school, occupational, and psychological functioning. The pace of studies has increased greatly in the past decade. In 2007, the American Medical Association released a report on the \"addictive potential\" of video games. The report con- cluded with a recommendation that the \"AMA strongly encourage the consideration and mclusion'of flnteme_!/ video game addiction' as a formal diagnostic d:soxdle{ in the upcoming revision of the Diagnostic and Statistical Manual of Mental Disorders-1V." ) The most comprehensive study to date in the Us used a national sample of over 1,100 youth aged 8 to 18, in which 8.5% of video game players were classified as pathological demonstrates that it is not a trivial number of people who are suffering damage to their lives because of their game play. School Performance . Several studies have documented a negative relation between amount of time playing video games and school performance among children, adolescents, and college students. The displacement hypothesis, that games dis- place time on other activities, is the most typical explana- tion for this relation. It could be argued, however, that the relation might be due to the children themselves, rather than to game time. It is highly likely that children who perform more poorly at school are likely to spend more time playing games, where they may feel a sense of mas- tery that eludes them at school. Nevertheless, each hour a child spends playing entertainment games (in contrast to educational games, which have been demonstrated to have educational benefits) is an hour not spent on home- work, reading, exploring, creating, or other things that might have more educational benefit. Some evidence has been found to support the displacement hypothesis. In one nationally representative US sample of 1,491 youth between 10 and 19, gamers spent 30% less time read- ing and 34% less time doing homework. Therefore, even if poor school performance tends to cause increases in time playing video games, large amounts of video game play are likely to further hurt their school performance. In short, the recent explosion in research on video game effects has greatly improved our understanding of how this medium affects its consumers. Several conclu- sions can be drawn without any reasonable doubt. First, there are many different effects of playing video games on the player. Some of these are short term, whereas oth- ers are long term. Second, the specific effects depend on a host of factors, including the content, structure, and con- text of the game. Third, the same game can have multiple effects on the same person, some of which may be gener- ally beneficial whereas others may be detrimental. Fourth, playing violent video games is a causal risk factor for a host of detrimental effects in both the short and the long term[s], including increasing the likelihood of physically aggressive behavior. Negative Effects on the Brain Studies have shown evidence that exposure to violent video games reduces the player's use of some brain areas involved in higher order thought and impulse control. In addition to behavioral-psychological theories explaining the relationship between media violence expo- sure and aggressive behavior, recently attention has turned to neuro-psychological theories. These theories attempt to identify areas of brain functioning that may be affected by media violence exposure and that may underlie aggressive behavior. As recently as June 2010, another study of violent video game effects on frontal lobe activity was published wherein it was concluded that playing a violent video game for only 30 minutes immediately produced lower activity levels (compared to a nonviolent video game) in Pprefrontal regions thought to be involved in cognitive Are Violent Video Games Harmful to Children and Adolescents? by Gantt and Slife _f' inhibition. This study shows that playing a violent video game for 30 minutes causes a decrease in brain activ- ity in a region of the frontal lobe that is known to be important in the ability to inhibit impulsive behavior. The study also suggested that . . . violent games may also impair emotional functioning when it noted that \"an impaired role of DLPFC (dorsolateral prefrontal cortex) in inhibi- tion, therefore, may yield impaired emotional functioning following violent video game play.\" Other studies of the neurological underpinnings of aggressive behavior, for example, indicate that a neural circuit that includes parts of the frontal cortex, amygdale, and temporal lobes is important in emotional regulation and violence. Research strongly suggests an underactiv- ity of brain inhibitory mechanisms in the frontal cortex and striatum, coupled with hyperarousal of the amygdala and temporal lobe regions, is responsible for chronic, explosive, and/or severe aggressive behavior. Research clearly indicates that areas in the frontal lobe and amygdale may be activated by viewing violent television and playing violent video games. With the use of functional magnetic resonance imag- ing (fMRI), research has shown a direct alteration in brain functioning from exposure to media violence. Research- ers found that teenagers who played a violent videogame exhibited increased activity in a part of the brain that gov- erns emotional arousal and the same teenagers showed decreased activity in the parts of the brain involved in focus, inhibition, and concentration, Youth who play a lot of violent video games (but who have not been diagnosed with a behavioral disor- der) show a similar pattern of brain activity when doing complex executive control tasks as youth who have been diagnosed with some type of aggression-related behavior disorder. This pattern is very different from control-group youth who do not play a lot of violent games (and who have not been diagnosed with a behavioral disorder). Youth who play a lot of violent video games show a deficit in a specific type of executive control known as proactive control. Proactive control is seen as neces- sary to inhibit impulsive reactions. This difference shows up in the brain wave patterns as well as in behavioral reactions. Additionally, video game violence exposure and aggressive behavior to brain processes have been linked reflecting a desensitization in the aversive motivational system. Repeated exposure to media violence reduces its psychological impact and eventually produced aggressive approach-related motivational states theoretically leading to a stable increase in aggression. Finally, in a functional magnetic resonance imag- ing study on players of the first-shooter game Tactical Ops: Assault on Terror, the violent portions of a video game activated the regions in the brain known to be active in fight-or-flight situations. In other words, the brain reacted to the fictional violence of a video game in much the same way as it reacts to real violence. In short, neuroscience research supports a critical Jink between perpetration of virtual violence with reduced activation of a neural mechanism known to e important for self-control and for evaluation of affect. These find- ings strongly suggest that focusing on the activity of pre- frontal cortical structures important for executive control could provide important 'mediational links in the relation- ship between exposure to violent media and increased aggression. 3. Recent Studies and Researchers Continue to Find Harmful Effects To Minors From Playing Violent Video Games In March 2010, leading researchers in the area of media violence from the United States and Japan worked together to conduct a meta-analytic procedure testing the effects of violent games on aggressive behavior, aggressive cog- nition, aggressive affect, physiological arousal, empathy/ desensitization, and prosocial behavior. In conducting their meta-analysis on the effects of video game violence, these researchers retrieved over 130 research reports which entailed scientific tests on over 130,000 participants. This study has been desctibed as \"probably about as exhaustive a sampling of the pre-2009 research literature as one could obtain and far more than that used in any other review of violent video game effects.\" This extensive meta-analysis of the effects of violent video games confirms what many theories predicted and what prior research about other violent mass media found: that violent video games stimulate aggression in the play- ers in the short run and increase the risk for aggression behaviors by the players later in life. The effects occur for males and females and for children growing up in Eastern and Western cultures. Also, the effects were stronger for more violent than less violent outcomes. From their overarching analysis, these researchers concluded that the scientific debate should move beyond the simple question whether violent video game play is a causal risk factor for behavior because: \"scientific literature has effectively and clearly shown the answer to be 'yes.\"\" Regardless of research method (experimental, cor- relational, or longitudinal) and regardless of cultures tested (East and West) the same effects are proven: expo- sure to violent video games is a causal risk factor for aggressive thoughts and 'behavior, and decreased empathy and prosocial behavior in youths. In fact, Dr. Anderson, one of three 2010 American Psychological Association Distinguished Scientist Lecturers, has stated that this recent meta-analysis on violent video games may be his Jast because of its \"definitive findings.\" 4. The Shortcomings of Purported \"Research\" Contesting the Scientific Studies Showing the Harmful Effects to Minors Playing Violent Video Games The Video Software Dealers Association and the Entertain- ment Software Association will likely contest the science showing the harmful effects of violent video games on minors. Apart from the self-serving motive for such oppo- sition, one need only consider a professional organization that clearly does not doubt the serious aggression-teaching abilities of violent video gamesthe United States Depart- ment of Defense. Both the U.S. Army and U.S. Marines have their own video games used to train soldiers as tacti- cal \"first-person shooters\" leading teams in \"close-quarters urban combat.\" Many of these military combat training videos, such as Full Spectrum Warrior and First To Fight have been adapted and placed on the commercial market for minors to play. Also, alleged \"scientific\" studies may be suggested by Respondents to argue that there are no harmful effects from violent video game playing. These \"findings\" can be explained by small sample size, poor test conditions, and chance. The simple response to these studies is the recent and clear findings of the meta-analysis comprising 130 studies of the effects of violent video games showing the like between violent video games and aggression. 11. Conclusion The scientific debate about whether exposure to media violence causes increases in aggressive behavior is over. All major types of research methodologies have been used, including experiments, cross-sectional correlational studies, longitudinal studies, intervention studies, and meta-analyses. For each category exposure to media vio- lence was significantly associated with increased aggres- sions or violence. Likewise, the harmful effects on minors from playing violent video games are documented and not seriously contested. M}xch research over several decades documents how witnessing violence and aggression leads to a range of negative outcomes for children. Negative outcomes result both. from witnessing real violence [and] from viewing media violence. The most recent comprehensive review of the media violence literature documents the \". . . unequiv- :;aal evidelnce th:{ media violence increases the likelihood ggressive and viol i i o _i;;[m T lent behavior in both immediate and In the end, we need only to circle back from this ris- ing ocean of research and return to simple commonsense. \"_Are Vk)Alen! Video Games Harmful to Children and Adolescents? by Gantt and Slife 139 Socier has a di:eft, rational, and compelling reason in marginally restricting a minot's access to violent video games. . .. Steven E. Gruel is a practicing criminal defen: and former federal prosecutor with over 25 yeatsseoztetzgz ence. Voted California's top \"SuperLawyer\" for three con- seutive years, he was previously the chief of the Major Crimes Section in the U.S. Attorney''s office. He has received alaw degree from the University of Wisconsin Law School. 140 t Taking Sides: Psychological Issues Patricia A. Millett 4 NO Brief of Amici Curiae in Case of Brown v. Entertainment Merchants Association Introduction and Summary of Argument As respondents explain, California's ban on the sale al:ld rental of certain video games to minors is subject to strict scrutiny because it directly regulates video games based on the content of a game, i.e., whether the game is deemed \"yiolent.\" California asserts that its law is necessary to \"prevent psychological or neurological har{n to minors who play violent video games.\" Under strict scr:,'mny, California must both provide \"substantial evidence\" that the video games it regulates cause psychological or neuro- logical harm to minors who play them, and de'monst'rate that the restriction will \"aileviate these harms in a direct aterial way.\" and n:;allfomia ;}'ms done neither. Indeed, California does not offer any reliable evidence, let alone substantial evi- dence, that playing violent video games causes psycholog- jcal or neurological harm to minors. Cal@a confesses it cannot prove causation, but points to studies that it says show a \"correlation\" between the two. But the evidence does not even do that. California and Senator Yee also cite studies that pur- port to show a link between the playing of violent video games and violent, aggressive, and antisocial behavior by minors. But in the court of appeals, California expressly disclaimed any interest in regulating video games sales and rentals to minors to prevent such conduct, and there- fore these studies are waived because the argument was waived. The studies are of no help to California in any event because they document neither a causal connection nor a correlation between the playing of violent video games and violent, aggressive, or antisocial behavior. Indeed, whether attempting to link violent mqm games with psychological and neurological harm or with violent, aggressive, and antisocial behavior, all of the. stud- jes that California and Senator Yee cite suffer from inher- ent and fundamental methodological flaws. o The survey of aggressive behavior. The courts below carefully considered this survey and cor- U.S. Supreme Court, 2010. rectly discredited it because the questions it posed are simply not valid indicators for actual violent or aggressive behavior and because it fails to account or control for other variables that have been proven to affect the behavior of minors. The laboratory experimental study of aggres- sion. This study, too, was rightly discounted by the courts below because it relies on proxies for aggression that do not correlate with aggressive behavior in the real world. The \"meta-analysis' of video game violence research. A meta-analysis combines the results of many other studies on a particular subject. But the accuracy and utility of any metam;lysis depends on the quality of the underlying studies Lt}em_selves. Put another way a meta-analysis of scnent"lcally unreliable studies cannot cure the studies' flaws. Here, the meta-analysis on whigh Senator Yee relies was compromised because it was bas_ed on studies that used invalid measures of aggression. \"Longitudinal\" studies of aggression. A longitludi- nal study analyzes participants on many occasions over an extended period. The studies that Sena- tor Yee cites are not longitudinal because they observed participants on only a few occasions and over just a short period of time. Add)onally, those studies both failed to account for other vari- ables that may explain aggressive behavior and used invalid measures of aggression. Neurosclence studies. These studies supposedly show a connection between playing violent video games and altered brain activity. The courts below properly concluded that they do not. Further, the neuroscience studies are rooted in fundamentally flawed statistical methodologies and do _not address the cause of brain activation and deactiva- tion in children. Methodological flaws are only the beginning of the studies' problems. Both California and Senator Yee repgat-y edly exaggerate the statistical significance of -{e studies' findings, failing to inform the Court of express disclaimers and cautionary statements in the studies about the nature of their findings. Finally, California and Senator Yee ignore a weighty body of scholarship, undertaken with established and reli- able scientific methodologies, debunking the claim that the video games California seeks to regulate have harmful effects on minors. Argument L. California's Asserted Interest in Preventing Psychological and Neurological Harm to Minors Is Not Supported by Any Reliable, Let Alone, Substantial Evidence A. California's Studies Do Not Show a Causal Link, or Even a Correlation, Between Playing Violent Video Games and Psychological or Neurological Harm to Minors California's ban on the sale and rental of violent video games to minors rests on the same flawed studies that court after court has rejected. The courts were right to reject these studies because they do not even establish the \"correlation\" between vio- lent video games and psychological harm to minors that California says exists, let alone the causation of harm that, as respondent explains, the First Amendment requires. Nor do the studies show a connection between playing violent video games and violent or aggressive behavior of minors, which explains why California disclaimed that interest below. First, California points to a 2004 study by Douglas Gentile of approximately 600 eighth and ninth-grade stu- dents. These students completed surveys that asked ques- tions about the types of video games they preferred and how \"violent\" they were. (The survey did not provide any definition of \"violent.\") The survey also recorded how often the students played the games; the students' hostil- ity level; how often they had argued with teachers during the past year; their average grades; and whether they had been in a physical fight in the past year. From the sur- vey answers, Gentile concluded that \"[a]dolescents who expose themselves to greater amounts of video game vio- lence\" were more hostile and reported getting into more arguments with teachers and physical fights and perform- ing poorly in school. Although California relies heavily on the Gentile survey, it has absolutely no relevance here. The survey examines only the purported connection between video game violence and \"aggressive behavior\" or \"physical aggression\" towards third parties. It does not study, and says nothing about, the psychological or neurological Are Violent Video Games Harmful to Children and Adolescents? by Gantt and Slife harm allegedly caused to those who play violent video games, which is the only interest that California defended below and thus is the only interest that is properly before this Court. Even if the Gentile survey were relevant, it simply does not say what California says it does. California states that the survey \"suggest[s] a causal connection between playing violent video games and aggressive behavior.\" It does no such thing. The survey makes absolutely no find- ing that exposure to violent video games leads to physical aggression. To the contrary, it explicitly cautions against making that inference: \"It is important to note . . . that this study is limited by its correlational nature. Inferences about causal direction should be viewed with caution.\" (\"Are young adolescents more hostile and aggressive because they expose themselves to media violence, or do previously hostile adolescents prefer violent media? Due to the correlational nature of this study, we cannot answer this question directly.\"). Beyond that, the Gentile survey is rife with meth- odological flaws that undermine even the suggested corre- lation. For example, the measures of \"aggressive behavior\" that Gentile employed are highly suspect. Having an argument with a teacherwithout any further explora- tion into the nature of the eventdoes not even suggest violent or aggressive behavior. And simply asking students whether they had been in a fightagain, without any fur- ther analysis of the eventis not a valid indicator for vio- lent or aggressive behavior. Additionally, there are many factors that may influ- ence youth violence or aggressive behavior, including: family violence, antisocial personality traits, and associa- tion with delinquent peers. . . . Because Gentile's survey failed to control for, or even consider, those other vari- ables, its conclusion that there is a correlation between video games and hostility to third parties lacks scientific grounding. In fact, controlling for gender alone removes most of the variance from which Gentile finds a correla- tion. In other words, the correlation Gentile claims to find is equally explainable by the effect of gender: boys tend to play more violent video games and tend to be more aggressive. Second, California points toa2004 study of 130 college students by Craig Anderson. That study measured the blood pressure of students before, during, and after play- ing selected video games and had students take a \"word completion\" test after playing selected video games. Based on the resulting measurements, Anderson concluded that the students' blood pressure increased while playing cer- tain video games he labeled \"violent\" and that game play \"increase[d] . . . the accessibility of aggressive thoughts.\" 142 | Takingsides: Psychological lssues The Anderson study is no help to California, because it does not show that a rise in students' blood pressure has any relationship to whether violent video games cause psychological or neurological harm. Nor does California show how \"aggressive thoughts\" leads to psychological harm. Laboratory experiments, like Anderson's, that mea- sure aggression immediately following the playing of a video game are common in the field of media effects research. And like Anderson's, these experiments rely on proxies for real aggressive or violent behavior, such as the participants' willingness to administer blasts of white noise against an unseen (and non-existent opponent). The problem is that the proxies bear no relationship to whether someone is going to act aggressively or violently in the real world. Similarly giving participants words with blank spaces and evaluating whether they make \"aggressive\" or \"non-aggressive\" words with the letters they fill in (ie., \"explo_e" could be completed as \"explore\" or \"explode\"), as Anderson did in his experiment, has no known valid- ity for measuring aggressive behavior (or even aggressive thinking). Third, California points to a 2004 study of fourth and fifth grade students by Jeanne Funk, and claims it \"found that playing violent video games was correlated with lower empathy as well as stronger pro-violence atti- tudes.\" But the Funk study specifically disclaimed any proof of causality. As Funk admitted, the children in her study whose scores indicated lower empathy or stronger pro-violence attitudes may simply have been drawn to violent video games. Moreover, the small sample sizejust 150 childrenand the failure to control for or consider any other variables undermine even the study's tentative conclusion of a correlation between violent video games and pro-violence attitudes. . . . B. California and Senator Yee Ignore the Large Body of Empirical Evidence That Shows No Causal Connection, or Even a Correlation, Between Violent Video Games and Harm to Minors California and Senator Yee ignore a wealth of recent empirical evidence disabusing the notion that violent video games are harmful to minors. Here is just a snapshot of that body of scholarship: A study of 603 Hispanic youths (ages ten to four- teen), recently published in The Journal of Pedi- atrics, examined various risk factors for youth violence, including video game violence, delin- quent peer association, family conflict, depres- sion, and others. The children listed television shows and video games and rated how often they viewed or played the mediaa reliable and valid method of evaluating violent media exposure. The children were then evaluated using the Child Behavior Checklist, a well-researched and well- validated tool for measuring behavioral problems in children and adolescents. A statistical analy- sis of the results revealed that exposure to video games had a negligible effect size and was not pre- dictive of youth violence and aggression. A study of 1,254 seventh and eighth-grade stu- dents examined the influence of exposure to vio- lent video games on delinquency and bullying behavior. The Entertainment Software Ratings Board ratings were employed as a standardized measure of participants' exposure to violence in video games. The study applied a multivariate sta- tistical method that considered other factors that might be predictive of aggressive behavior (such as level of parental involvement, support from others, and stress). This study did not use abstract measures of aggression, but instead focused on specific negative behaviors such as delinquency and bullying. A statistical analysis revealed insig- nificant effect sizes between exposure to violent video games and delinquency or bullying. The authors accordingly concluded that exposure to such games was not predictive of delinquency or bullying. A study of 213 participants examined the influ- ence of violent video game play on aggressive behavior. The 213 participants were divided into a 75-person treatment group that played a sin- gle game, Asheron's Call 2, a type of \"massively multi-player online role-playing game\" that is \"highly violent\" and has \"a sustained pattern of violence,\" for at least five hours over a one-month period, and a 138-person control group that did not play the game. Participants then completed self-reported questionnaires that included a range of demographic, behavioral, and personality vari- ables. Aggression-related beliefs were measured according to the Normative Beliefs in Aggression general scale, a well-validated scale for measuring Peliefs about the acceptability of aggression, and aggressive social interactions were measured using specific behavioral questions. Both measurement techniques had been successfully used in previ- ous studies of violent television and video game effects. The results of this study found no effects associated with aggression caused by playing vio- lent video games. These studies are just the tip of the iceberg. They rate barely a mention in Senator Yee's brief, which disparages them as \"alleged 'scientific studies'\" that involved \"small sample size, poor test conditions and chance.\" That is wrong. The studies employed large sample sizes, long- standing and validated measures of aggression, an supe- rior statistical controls. Ironically, the studies also include t%le work of researchers whom California and Senator Yee C|t_e favorably. For example, as noted above, California relies on the research of Jeanne Funk. But, in a separate study that California does not mention, Funk \"fail[ed] to find\" evena correlation between violent video games and aggressive emotions and behavior. Notably, this second _Funk study employed the Child Behavior Checklist, which is a better validated measure of aggression than measures utilized in the studies on which Californi e fornia and Senator o _AreViolent Video Games Harmful to Children and Adolescents? by Ganttandife | : At minimum, the scholarship that California and Senator Yee ignore belies the notion that the \"substantial evidence of causation\" standard imposes an \"insurmount- able hurdle\" on science or legislatures. These studies show unequivocally that the causation research can be done, and, indeed, has been done. The problem confrontin California and Senator Yee thus is not the constitutional standard; it is simply their inability to meet that standard in this case because validated scientific studies prove the opposite, leaving no empirical foundation for the assertion that playing violent video games causes harm to minors. PaTriciA A. MiLLeTt has argued more than 30 cases before the Supreme Court, and was named one of the 100 most influential lawyers by the National Law Journal. She gradu- ated summa cum laude from Harvard Law School