1. Game Console Availability

In many jurisdictions, including the United States and Europe, the video game market is dominated by console games. In the case of Turkey, video game software for use with game consoles is subject to high piracy rates. As a result, Turkey’s video game market is primarily an online game market, with revenues from this segment constituting nearly all of video game revenues. Internet cafés have become one of the primary venues in Turkey at which users play online games offered by domestic game operators.

2. Game Approval and Content Review

This section provides a general overview of the content review and approval process for

imported games and the respective registration process.

In addition to the various licenses that are required for video games in Turkey, each imported game must also receive approvals from the Ministry of Culture and Tourism prior to commercialization. Furthermore each domestic game must be registered with a designated sub-committee within the Ministry of Culture and Tourism.

The Ministry has broadly promulgated a variety of measures relating to game content, which one may infer apply to online games. These regulations are drafted in broad general terms and prohibit content that:

• Incites ethnic hatred or racial discrimination or undermines national solidarity
• Disseminates rumours, disrupts social order or undermines social stability;
• Propagates obscenity, pornography, gambling, violence or instigates crimes;
• Insults or slanders others, or otherwise infringes upon the legitimate rights of others;
• Endangers social morality
• Is otherwise prohibited by the laws, or administrative regulations of the State.
• Induces minors to imitate acts that are against social morality, or any illegal criminal acts, or any horrible or cruel content that impairs the physical and mental health of minors.

3. Content Review Process

All video games imported for operation within Turkey must be submitted to the Ministry of Culture and Tourism for content censorship review. The Ministry of Culture and Tourism censorship committee shall conduct a preliminary examination, after the successful completion of which open beta testing of the game may begin. Following open beta testing, the Ministry of Culture and Tourism will make a final determination with respect to the game.