Occasionally a game may receive a rating other than what a publisher might want. What kinds of changes do publishers make to change a rating?

PV: That's really up to the publisher, the type of content in their game and what rating they're shooting for. We provide guidance to publishers about elements that impact raters' determinations, but we never tell them what specific content they should or shouldn't change or how to do so. The content that goes into games is completely at the discretion of the games' creators. Our job is never to dictate content, but rather to evaluate it and assign a rating that we think will be helpful to consumers.

How frequent are appeals? A rough number would be nice -- say, N games out of every 1000.

PV: The appeals process has actually never been used, so the number you're looking for is zero out of 15,000 plus games rated! On the other hand, it's fairly common for publishers to revise and resubmit their games when they would prefer to release a game with a different rating than the one we assigned.

Ah, so no appeals. If there were an appeal, would the original raters be included in the appeal process, or is their original recommendation the only part they play into the appeal process?

PV: It's the latter. The appeals process doesn't involve the raters themselves. A group of industry members, retailers and other professionals would hear presentations both from the publisher and the ESRB, look at other materials they may deem relevant, and make a determination on whether or not the rating should stand.

The ESRB says that its raters are "trained to consider a wide range of pertinent content and other elements in assigning a rating." Could you elaborate on the kind of training the ESRB provides? Do raters get periodic training to keep them informed of the videogame industry and ratings of other games? Perhaps something akin to the continuing legal education courses that an attorney might take each year.

PV: The training we provide to raters is very intensive. It generally lasts from three to six weeks. It involves, but is not limited to, guided review of footage from past submissions; education about the types of content raters need to be on the lookout for; instruction on identifying screen elements that denote interactivity, and understanding how elements such as reward systems factor into rating assignments. They're put through mock rater sessions with games that were previously rated since, as I said earlier, consistency is important. And the training is definitely ongoing. After new or unique rating issues have been identified during any particular rating assignments, those issues are fully vetted with all of the raters as part of ongoing training by ESRB staff. And of course raters are constantly gaining more experience by virtue of rating games day in and day out.

Could you give us an example of a game whose rating process brought up particularly thorny issues, perhaps with both its rating and with its descriptors (which depend on the choice of rating). If you can't name a specific game, perhaps details about an example where raters had to work especially hard to arrive at a final rating and set of descriptors? What were the issues involved and how were the questions resolved?

PV: I can't speak to the rating process for any one game, but generally speaking, things like language -- bathroom humor, plays on words, slang -- fictitious or non-descript substances, or use of religious imagery can often be tricky. The presence of sensitive social issues in games, like sexual or racial stereotyping for example, have also led to internal debate about how best to address them from a ratings standpoint.

Though it might surprise people to hear it, low-level or cartoon violence actually tends to be something that receives a lot of thought and discussion. Take for instance an animated character that smacks another over the head with a frying pan. Is that Comic Mischief or Mild Cartoon Violence? To a degree, that's going to depend a lot on the depiction itself. What happened to the character when he got hit? How malicious or realistic was the violent act? How often does it occur? Context is also a consideration. What prompted the action? Is it player-controlled, or is it in a cut-scene?

Then, of course, the rating category figures in since the descriptors are applied relative to the rating assigned. Is this kind of content justification for assigning an E10+ or even a T, or is it still within an acceptable range for an E-rated game? The process we have in place and the people that are involved in it are extremely thoughtful about these kinds of things.

Some of your raters are parents. Are they instructed that they should think as a parent while rating games which their own children might play?

PV: We ask that the raters view content and assign ratings from the perspective of what they think would be most helpful to the average consumer, parents in particular. Our preference for hiring raters that have experience with children is so that they can apply that knowledge when considering content and assigning ratings that are intended to provide helpful guidance to parents.

Do raters apply their own moral standards (on subjects like violence, substance abuse, and sexuality) to guide their rating recommendations? Or, are they merely to apply a standard that the ESRB has set out for them?

PV: It's really a combination of both. Rating games is an inherently subjective practice in the sense that content is always going to be interpreted in different ways by different people. So part of the equation is the raters' own views on content, but as I said, parity and consistency play important roles as well.

Are those parents allowed to involve their children in the rating process?

PV: The submission materials that raters review are confidential, and they're strictly forbidden from discussing the content of those materials outside of the office. But we expect a rater's own life experience and the developmental experiences of their children to play a role in guiding their judgments, and we do not try to inhibit that as part of the rating process.