What I Would Tell The FCC About Games

In the American Recovery and Reinvestment Act (the Stimulus Act), Congress charged the FCC with developing a National Broadband Plan by February 2010.  Last month, Blair Levin, the FCC official overseeing the broadband plan, called the 8,500 page record developed so far "unhelpful." 

On August 5, the Chairman agreed, saying, “We need everyone, every stakeholder, to step up, to meet the moment, to tackle the data issues, to tackle the policy issues, and to take this process as seriously as it deserves.  I don’t think that’s happened yet but I’m confident that it will.”

To improve the record, the FCC is holding a series of public workshops this month in Washington.  For fun, here is what I would tell the FCC about games and broadband, if given the chance.

If I were a mobile game developer:  I would participate in the workshop on Technology/Applications and Devices on August 27.  I would tell the FCC the explosion of the Apple iPhone shows that quality devices can and will drive adoption and use of mobile broadband services.  I would add that six of the top paid iPhone applications for 2008 were games and that 14 of the top 20 all-time paid iPhone applications are games. 

I would tell them that mobile games also are popular on "feature phones," although the "walled garden" effect hinders their growth.  Moreover, I would point to the unique ability of mobile games to integrate social and location elements, as was done in 2008 Independent Games Festival Mobile winner, PhoneTag Elite.  In short, games are one of the services mobile consumers use today and will want to use in the future.

I would say that there are two keys to growth in mobile games in a broadband world.  First, there is a need to improve the consumer experience in finding, downloading and buying mobile games.  Users should have the right and ability to access mobile games from the provider of their choice, whether it be the mobile carrier or a third party app store. 

The FCC's wireless policies should encourage more and better ways for consumers to conduct commerce using their mobile phones.  In the past, the sale of applications has been closely controlled by the wireless carriers, often to the frustration of mobile game developers. 

We are starting to see improvements, but the FCC should prohibit mobile carriers from unreasonably restricting access to applications or types of applications on its portals.  In addition, the FCC should ensure that third party portals have the access necessary to verify subscribers, to deliver games to mobile devices and to bill customers for the services they purchase.

Second, I would say that mobile growth also can come from devices not traditionally viewed as phones.   Handheld game devices are flourishing, as are a variety of non-phone devices such as GPS receivers, e-book readers and netbooks.  These devices can deliver even more consumer value when interconnected via broadband.  The Commission should encourage MVNO relationships (like the Amazon Kindle) and should authorize both licensed and unlicensed "white spaces" devices as soon as possible.  

We need more companies like Amazon reselling data services in a manner transparent to their target audience.  Why shouldn't the PSP Go and the DSi integrate the download distribution with the device itself?  Or, perhaps a new mobile device will be introduced that is somewhere between a console and a mobile phone.  If that happened, we also could see the rise of mobile online gaming, something that would open new opportunities for game developers.

If I were a PC game developer:  I would participate in the Fixed Broadband workshop on August 13.  This workshop is focused on bandwidth needs and service level arrangements for wireline networks.  I would say that PC gaming has played a significant part in both the advancement of computing capabilities and in adoption of broadband by consumers.  Gamers tend to buy the highest end PCs, equipped with faster processors and advanced graphics cards.  Gamers also were early adopters of cable and fiber-based broadband and are a significant portion of the market for packages with the higher download speeds.  

I would say that the market today is only in its infancy.  Ten years ago, we thought that 56K dial up was "fast enough."  Ten years from now, 1.5 Mbps and even 3 Mbps will fall in the "how could we have lived with that?" category.  We need to set an ambitious goal for through-put -- 100 Mbps service is a good start -- but broadband goals also should include minimum standards for quality of service.  In gameplay, latency and jitter play as significant a role as do theoretical maximum upload/download speeds.  

I also would discuss the role of social and community features in improving applications.  Social networks have proven the value of connecting people to one another on the Internet, and they have shown that doing so effectively can generate significant economic activity.  Not surprisingly, games have become one of the biggest hits on social networks.  Gaming is the ultimate social experience, whether one plays Texas Hold 'Em, Farmville, Diner Dash or World of Warcraft. 

Users will continue to look for new and improved ways of communicating with each other while experiencing the social network or game.  Thus, we expect to see more of in-game voice, video and other communications technologies as broadband capabilities increase.  Interoperability among applications will become a bigger issue as these methods of communicating increase.  (So, just as the Commission is now being asked to classify SMS, in the future it may have to determine the appropriate interoperability framework for non-interconnected VoIP and video.)

If I were a game industry organization, venture capital firm or major publisher: I would participate in the Economic Growth and Job Creation workshop on August 26.  I would argue that games do not deserve their reputation as the refuge of anti-social teenage boys or slackers.  Games are entertainment, just like movies, TV and other diversions.  Moreover, the games business is a multi-billion dollar business offering persons of all ages entertainment of value. 

I would argue that the Commission should consider the potential effects of broadband in expanding the market for interactive entertainment, venture backing of content creators and the game development job markets in this country.  I would argue that more broadband is good for the entertainment industry, as consumers will find increased and more engaging gaming experiences online and will be better able to purchase and download entertainment that they want, directly to their homes.  

Finally, I would note the impact that games and game technology have for training, education and employment purposes.  A lot of cognitive research shows that the "learn by doing" method of games is an effective way to teach students and train workers. 

I would discuss the rise of "serious" games and describe the many ways in which game technology is used by businesses, hospitals, government and others for these purposes.  I also would discuss the efforts of non-profit groups to increase the use of interactive media to educate children.  Games offer a new frontier of possibilities in these fields. 

This is just a start in how game developers can raise their profile in Washington in order to present a positive image of the industry to those who too often attack games for political purposes.  I hope you will comment with additional thoughts or ideas you would like to convey to Washington.