Hi, I’m Leon, a PhD Fellow at the IT University of Copenhagen.
I research video game law, particularly the regulation of loot boxes, gacha, and other gambling-like monetisation mechanics in video games that offer random rewards. I am trained in English law and have been Called to the Bar of England and Wales. I use empirical legal research methods to assess whether companies are complying with various rules in different countries through fieldwork, and I advise on how compliance could be improved.
I also conduct traditional, doctrinal legal research and psychology studies, including surveys and experiments. I am passionate about open science: I preregister research methods, share data, and even conduct registered reports (including likely the first one in the world in the legal discipline). I also dabble in some research on gameplay time and videogaming ‘addiction’ and the intersections between cryptocurrencies, NFTs, gaming, and gambling.
I am actively involved in advising on policymaking across the world. I have been invited to testify before an Australian House Committee. My research has been referenced (twice!) in the House of Lords and relied upon by UK, US, EU, Spanish, Danish, Dutch, Swedish, Australian, and Brazilian policymakers and regulators. The Belgian Minister of Justice has publicly accepted my research critical of his government.
I put my research results into practice by making complaints against companies either through relevant regulators or directly. Through my actions, many key precedents in video game advertising regulation have been established in the UK, and companies have been fined in the EU for non-compliance. Companies and industry self-regulators have taken direct compliance and remedial actions following my research, e.g., amending the app store listings of many popular games to ensure consumer protection.
My award-winning research has received worldwide coverage by The Guardian, The BBC, The Times, CNBC, NPR, RTÉ, The SMH, Ekstra Bladet, Politiken, El Español, El Economista, Der Standard, Het Nieuwsblad, HLN, ČT24, SCMP, NME, The Daily Beast, New Scientist, Thanh Niên, and leading video game media, e.g., GamesIndustry.biz, GameSpot, Eurogamer, and Game Developer, amongst others.
I was recognised as a Forbes 30 Under 30 and a Berlingske Talent 100 for my policy advocacy.
I have won multiple research and impact awards, a prestigious Danish grant, and multiple ECR grants, totalling over £71,000 in value. Current projects focus on using EU law (e.g., the Digital Services Act) to scrutinise gambling and video game advertising using social media ad repositories. I also hope to use data protection law (e.g., the GDPR) to access research data that the industry refuses to share publicly fearing that the results will be contrary to their commercial interests.
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Leon Y. Xiao, LLB, LLM, FRSA, FRSPH, AFHEA
Talent 100, Berlingske (2024)
EliteForsk-rejsestipendiat, Danish Government (2024)
30 Under 30, Forbes (2023)
Future Class 2022, The Game Awards (2022)
Game Changer, GamesIndustry.biz (2021)
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Contacts and Social Media
Email: lexi@itu.dk; leon.xiao.y@gmail.com
Twitter: @LeonXiaoY
LinkedIn: Leon Xiao
ORCID: 0000-0003-0709-0777
Conflict of Interest Statement: link
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Attending soon:
Society of Legal Scholars (Bristol); Video Game Cultures 2024 (VCG 2024): The Other Conference (Birmingham); ECREA (Ljubljana, Slovenia); Central and Eastern European Game Studies Conference 2024 (CEEGS 2024) (Nafplio, Greece); Esports Research Network 2024: Where Worlds Collide (London); Lisbon Addictions (Lisbon, Portugal)
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I have been invited by the Department for Culture, Media and Sport (DCMS) of the UK Government to provide advice on its technical working group for loot boxes and the Video Games Research Framework. I was also invited to advise the Danish Competition and Consumer Authority, the US Federal Trade Commission (FTC), and the Dutch Authority for Consumers and Markets, amongst many other policymakers and regulators around the world. My research was referenced on behalf of the UK Government in the House of Lords to support its regulatory position (Hansard: HL Deb 13 Oct 2022, vol 824, col 890); during debates in the Lords on the Online Safety Bill (Hansard: HL Deb 17 July 2023, vol 831, col 2152); and extensively in evidence to an Australian parliamentary committee and the Committee’s eventual report (pp. 138–146). My legal analysis of EU consumer protection regulations has been incorporated into the UK Advertising Standards Authority’s guidance on advertising in-game purchases (pp 9–10) and the UK Government’s response to the loot box call for evidence (paras 202–207). I was cited in class action complaints filed in California and two Spanish consultation papers on loot boxes. I co-won the impact prize at the 2023 annual conference of the Society for the Study of Addiction. I have also been invited to advise NGOs, such as UNICEF España.
I hold law degrees from Durham University and City, University of London and also studied on exchange at the National University of Singapore. I am a Fellow of the Royal Society of Arts (FRSA), a Fellow of the Royal Society for Public Health (FRSPH), and an Associate Fellow of the Higher Education Academy (AFHEA). Previously, I was a Lord Denning Scholar at The Honourable Society of Lincoln’s Inn and held visiting appointments at KU Leuven (Belgium), The Jagiellonian University (Poland), Queen Mary University of London (UK), Stanford Law School (US), University of Nottingham Ningbo (China), Yonsei University (Korea), and Leiden Law School (the Netherlands).
Recent News
23 July 2024: A comprehensive overview of loot box regulation around the world (updated to the end of 2023) is available in the Gaming Law Review via: https://doi.org/10.1089/glr2.2024.0006. Thanks to the AFSG and Greo for open access funding.
10 July 2024: The UK advertising regulator upheld my complaint in Ruling A23-1239057 Electronic Arts Ltd: https://www.asa.org.uk/rulings/electronic-arts-ltd-a24-1239057-electronic-arts-ltd.html. This precedent established that video game companies must prominently and clearly disclose the presence of loot boxes, rather than disclose using obscure methods, in video game advertising.
19 June 2024: I was quoted and cited extensively in the loot box section of the Public Health Approaches to Tackling Gambling-Related Harms in NI inquiry report of the Northern Ireland Assembly All Party Group (APG) on Reducing Harm Related to Gambling (pp. 29–31) after being invited to give oral and written evidence: https://www.gamharmapg.org/publications/inquiry-report-public-health-approaches-to-gambling-in-ni.
21 May 2024: My research was cited multiple times in the Council of Europe International Co-operation Group on Drugs and Addictions (Pompidou Group) Risks and Harms associated with Online Gaming and Gambling report (pp. 23, 28): https://web.archive.org/web/20240716200141/https://rm.coe.int/p-pg-it-2024-2-report-risks-and-harms-online-gaming-and-gambling-final/1680b07d35.
29 March 2024: My ASA complaints against companies for failing to disclose loot box presence was featured in The Guardian: https://www.theguardian.com/society/2024/mar/29/video-game-companies-developers-loot-boxes-regulator-complaints-rules.
20 March 2024: The UK Advertising Standards Authority has upheld three complaints I made about social media advertising not disclosing the presence of loot boxes: https://www.asa.org.uk/rulings/electronic-arts-ltd-a23-1222185-electronic-arts-ltd.html; https://www.asa.org.uk/rulings/jagex-ltd-a23-1216471-jagex-ltd.html; and https://www.asa.org.uk/rulings/miniclip--uk--ltd-a23-1216455-miniclip--uk--ltd.html.
16 March 2024: Berlingske included me in its annual Talent 100 list. https://www.berlingske.dk/talent-100/han-er-26-aar-og-allerede-verdens-nok-foerende-ekspert-paa-sit-omraade.
26 February 2024: I was awarded an EliteForsk Travel Grant 2024 by the Danish Ministry of Higher Education and Science. This was presented by HM The Queen of Denmark and the Minister of Higher Education and Science. I will visit 🇨🇳, 🇰🇷, 🇳🇱, and 🇬🇧 to assess the effectiveness of loot box regulation globally. 🌍🌏 My profile piece for the award: https://ufm.dk/forskning-og-innovation/forskningsformidling/eliteforsk/prismodtagere/prismodtagere-2024/eliteforsk-rejsestipendierne-2024/leon-y-xiao.
15 January 2024: I discussed loot box regulation with the Gambling Related Harm APPG and Peers for Gambling Reform at an evidence session for the APPG Gambling White Paper Inquiry.
21 December 2023: I was cited in the DCMS Committee report in relation to how industry self-regulation of loot boxes must be treated with scepticism due to my previous empirical research finding poor compliance (p. 27, para. 60): https://publications.parliament.uk/pa/cm5804/cmselect/cmcumeds/176/report.html.
5 December 2023: I published my annual accessible summary on loot box regulation around the world at GamesIndustry.biz: https://www.gamesindustry.biz/loot-box-state-of-play-2023-a-global-update-on-regulation.
4 December 2023: My research was cited in the Swedish Psychological Defence Agency report Malign foreign interference and information influence on video game platforms: understanding the adversarial playbook (p. 41): https://web.archive.org/web/20240409105615/https://mpf.se/download/18.660bf8cf18c8acbdb7930bc8/1704208301549/mpf-skriftserie-23-03-malign-foreign-interference-and-information-influence-on-video-game-platforms-understanding-the-adversarial-playbook.pdf
16 November 2023: I was given an Honourable Mention in the 2023 round of MCV/DEVELOP’s 30 Under 30: https://mcvuk.com/business-news/mcv-develops-30-under-30-2023/.
22 October 2023: My paper on how the Epic, Sony, Microsoft, and Nintendo stores also did NOT implement the PEGI loot box presence warning label has been accepted for publication in ACM Games: Research and Practice. Postprint: https://doi.org/10.31219/osf.io/sbtcf.
4 October 2023: The UK Advertising Standards Authority (the advertising self-regulator) has upheld two complaints I made regarding how Hutch Games failed to make disclosures about the presence of loot boxes within two of its games. For the Apple App Store decision, see: https://www.asa.org.uk/rulings/hutch-games-ltd-a23-1196857-hutch-games-ltd.html. For the Google Play Store decision, see: https://www.asa.org.uk/rulings/hutch-games-ltd-a23-1196862-hutch-games-ltd.html. UK companies should take note and comply! EU companies should also do so, as this rule is based on nationally implemented EU consumer protection law.
27 September 2023: After two years of peer-review at five journals, our study on loot box probability disclosures in the UK in 2021 has finally been published in PLOS ONE: https://doi.org/10.1371/journal.pone.0286681.
15 September 2023: The relationship between loot box spending and problem gambling replicated in China, whew! We also consider other potential risk factors for loot box harms. Also contains interesting reflections on the previous research methodology of giving the problem gambling scale to all participants. Published now in Addictive Behaviors: https://doi.org/10.1016/j.addbeh.2023.107860.
10 August 2023: Our study questioning the effectiveness of video game play time restrictions placed on young people in China using big data provided by Unity Technologies (7 billion+ hours!) was published in Nature Human Behaviour: https://doi.org/10.1038/s41562-023-01669-8.
17 July 2023: Our study on the apparent failure of the Apple App Store to enforce its own platform rules concerning loot box probability disclosure was highlighted during debates on the Online Safety Bill (Hansard: HL Deb 17 July 2023, vol 831, col 2152).
15 July 2023: Our study finding that popular iPhone games in the UK were not making loot box probability disclosures as required was featured in The Guardian: https://www.theguardian.com/society/2023/jul/14/more-than-850-people-referred-to-london-clinic-for-video-game-addicts-gambling-style-features-loot-boxes.
20 June 2023: I was invited to present before the Responsible Gambling Advisory Council of the Spanish Directorate General for the Regulation of Gambling [Dirección General de Ordenación del Juego (DGOJ)]. Presentation slides: https://doi.org/10.31219/osf.io/s357p. Press release: https://www.ordenacionjuego.es/en/noticia-CAJR_20230620.
June 2023: Our study on UK loot box probability disclosures will soon be published in PLOS ONE: [link forthcoming]. Featured by Tech Xplore: https://techxplore.com/news/2023-06-reveals-loot-probability-disclosure-transparency.html. [This was delayed to October 2023.]
23 May 2023: The story broke that PEGI has taken enforcement action (https://pegi.info/page/complaints-and-enforcement-cases) against Diablo Immortal (Activision Blizzard) and Hunt: Showdown Bounty Hunter - Limited Edition (Plaion) for failing to duly report loot box presence and thusly obtaining a PEGI rating based on incorrect information. Each company was fined €5,000: https://www.gamesindustry.biz/activision-blizzard-plaion-fined-for-not-disclosing-loot-boxes.
29 March 2023: My registered report on the ESRB, PEGI, and IARC loot box presence warning label has been published in Royal Society Open Science: https://doi.org/10.1098/rsos.230270
28 March 2023: Great to learn that 4 pieces of research that I co-authored or sole-authored will be presented at DiGRA 2023 in Spain.
7 March 2023: My stage 2 registered report on the ESRB, PEGI, and IARC industry self-regulation requiring loot box presence warning labels (‘In-Game Purchases (Includes Random Items)’) has been recommended by Chris Chambers: https://rr.peercommunityin.org/articles/rec?id=404
7 March 2023: I was recognised in the Forbes Under 30 Europe list under the Games & Sports category: https://www.forbes.com/profile/leon-y-xiao/.
2 March 2023: I wrote a short piece for a debate series on whether it is appropriate to collaborate with the technology industry when conducting academic research. I reflect on my personal experience and make the case that some studies are better off without collaboration, at least initially: https://doi.org/10.1111/camh.12644.
1 March 2023: I was called as a witness to give oral evidence to the Australian House Standing Committee on Social Policy and Legal Affairs in relation to loot box regulation. My opening statement: https://twitter.com/LeonXiaoY/status/1630927402950860802. Watch the Q&A in full: https://parlview.aph.gov.au/mediaPlayer.php?videoID=605886 (Timestamps: 10:40:00–11:03:38).