ARCANIX’s Oscar Clark on the EU’s DFA, Lightning Lessons, and the Primacy of Player Value, Part 1

Last October, Player Driven’s founder, Greg Posner, hosted Oscar Clark on the podcast. Clark is the Co-Founder and Director of ARCANIX, a “decision intelligence platform for games.” Prior to ARCANIX, among other notable positions around the gaming industry, Clark was Strategy Director at Colossal Games (which developed and released Commando Jack and other tiles during his tenure), architected Sony’s Online Virtual World, PlayStation Home (which shut down in 2015, but I remember that proto-metaverse with fondness!), and put in a few years at Unity Tech (where he worked on a precursor to Unity Ads as well as social game development tools).

A frequent lecturer and speaker, Clark also just published a new book, Playing with Balance: Game Economy Design. Our focus here will be the content of last October’s podcast, but perhaps we’ll be able to coordinate with Clark and double-click on his new book later this year.

Clark hails from Aldershot, England, which is southwest of London, and I was lucky enough to catch up with him irl at GDC 2026.

We’ll circle back to ARCANIX, the roots of his Lightning Lessons, and the importance of delivering player value in part two of this profile, which should post next week. Our main focus below is why Clark was so hot under the collar about the EU’s proposed Digital Fairness Act late last year. He was profoundly concerned that it could set back the industry that Clark has spent decades of his working life building up and supporting, unless key aspects of the legislation are amended in short order.

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An “Evil, Moustache-twirling, Top Hat Wielding Monetization Idiot” Has Grave Concerns About the EU’s Digital Fairness Act

The first question Player Driven founder and host Greg Posner put to ARCANIX’s Oscar Clark late last year involved a letter that Supercell’s Co-Founder and CEO, Ilkka Paananen, had just posted to LinkedIn. The letter raised an alarm about the European Union’s proposed Digital Fairness Act (DFA). Paananen painted a bleak picture of, potentially, market-breaking impacts for regional purveyors of free-to-play (F2P) and Live Ops video games especially.

The proposed legislation covers a lot of topics and it’s still in the drafting and consultation phase. The DFA, however, is on track to reach a fairly finalized version in the third quarter of this year. The legislation could be voted on by the European Parliament and the Council of the European Union as early as next year.

“I’ve got some track record with Ilkka,” Clark told Posner. “Ilkka is one of the best humans I know. I’ve known him since 2003. One of the first mobile games I ever put live was one of his when he was doing a company called Sumea. I still occasionally get hugs when I see him.”

To contextualize the potential dangers that he and Paananen see lurking in current DFA, Clark told Posner it would be helpful to go “back in time, into the time machine of GDC 2015. I’m giving a talk called the magic of…what’s the magic of habit?”

The talk in question, “Spellbound: Asking Questions About Habit Forming Game Design,” is in the GDC Vault if you happen to have a subscription. The tldr version is that the lecture, which was given when Clark was at Unity, proposed that F2P game designers must be careful to, yes, attract and retain as many players as possible, but do so in a way that hey stay on the “social good” and ethical side of what can be a psychologically manipulative line. There’s a careful balancing act to be struck in this regard (hey, maybe someone should write a how-to book on balancing video game economies?!).

“Is free-to-play evil or not?” Clark asked Posner. “That was the fundamental premise I was working on. I think that habit forming experiences can be incredible and amazing. However, we have a responsibility, particularly to vulnerable players.”

“I must have done something right because I annoyed all the people in the room [at GDC 2015] who thought free-to-play was evil and annoyed all the people in the room who thought free-to-play was pure as snow. So that, to me, is a massive triumph. Now, why does that matter? Why am I referring to that?”

On the one hand, Clark posited, there can be predatory, dark design patterns used in video game design and development processes, and if that happens then “bad actors need to be reined in. Now, how do you deal with bad actors? Well, there’s one way, which is regulation. The other way, which is you have a self-regulatory framework. Now we’ve had some of this self-regulatory framework in place. One example is loot crates. Now, obviously bad things happened, or at least bad things were interpreted about what was happening.”

In the middle of his time-bending jaunt to 2015, Clark decided to take Posner on a side quest to 2017. If you’ve seen the 2019 film Avengers: Endgame, you may remember its “time heist” segment in which Tony Stark and Steve Rogers time-traveled inside a larger time travel loop. It was like that.

“I think it’s worth the stepping back a bit about Battlefront II,” said Clark.

Okie dokie, down the virtual rabbit hole we go.

“There was a revolt about how bad it was,” Clark added. “That should be a lesson for everybody in the industry.”

Let’s flesh out the context of Star Wars Battlefront II’s loot box…rebellion. It was a big deal at the time, and its embers are still smoldering…not unlike Jedha City…somewhere between gamers, studios, lawyers, and legislators.

Developed by DICE and published by Electronic Arts, the action-shooter put players in the virtual shoes of well-known Light Side and Dark Side characters from around the Star Wars universe. (Note: Gamespot has an extended rewind of the game’s loot crate-related saga through the first week of release if you want a complete blow-by-blow.)

Left: Oscar Clark delivered a session at GDC 2015 on ethical economy balancing in F2P games. Right: Promotional art for EA’s controversial 2017 title, Star Wars Battlefront II.

The key beats of the loot box firestorm are as follows:

• It was clear months prior to release that online multiplayer would be a central pillar of Star Wars Battlefront II’s gameplay
• The game’s class-and hero-focused progression system involved its Star Card system
• The associated cards came in four tiers and were randomized in loot boxes that players could earn by grinding or buy with irl money
• Shortly after the beta opened in October 2017, players flocked to Reddit and other social networks to complain that the Star Card system felt too pay-to-win
• A trial release on Xbox and PC followed in early November, and more players went on Reddit in particular, and expressed concern that in-game purchases and the long-term progression system overlapped too much
• An EA rep commented on this thread…and it didn’t go over well
• The comment became Reddit’s most disliked ever, in fact, with >675,000 downvotes
• With the sky falling at DICE/EA, the game’s microtransaction system was ripped out on the eve of its commercial release, and DICE’s GM, Oskar Gabrielson, stated that “many of you feel there are still challenges in the design. We’ve heard the concerns about potentially giving players unfair advantages. And we’ve heard that this is overshadowing an otherwise great game.”

Star Wars Battlefront II did, ultimately, reintroduce its microtransaction store in April 2018—but the items in it were purely cosmetic. As with most, if not all, competitive video games, there’s a third rail for players that involves pay-to-win versus skill-to-win scenarios. They nearly always sniff out and despise the former approach. DICE/EA had backtracked to this well-established line that’s, arguably, as much about ethics as about gambling, legal issues, or PR (Belgian authorities came poking around once the Reddit downvote went viral).

It’s about money as well. Star Wars Battlefront II was a commercial disappointment. EA’s initial projection was for ten million copies sold, but the game struggled to reach nine million sold through early 2018. The 2015 franchise reboot sold significantly better, and it’s worth underscoring that EA undoubtedly expected premium Star Cards to augment the base game’s revenue significantly.

Coming back to Clark’s point, the loot box controversy was a case study of what can happen if a studio comes down on the…Dark Side…of an ethical monetization line that players have a huge part in defining. These controversies can draw the attention of politicians.

Clark didn’t suggest all politicians are “out to get” game studios/publishers. What he did imply is that when politicians look for a “solution” to a perceived “problem” in the video game industry, they’re more likely than not to reach for a legal remedy since that’s the hammer in the hands. If that hammer comes down on the head of real or perceived unethical in-app purchase “nails,” Clark further implied, that hammer can miss the mark and deliver an unintended, negative blows…that can leave a Jedha City-like smoldering crater.

“There is a whole bunch of people who don’t believe that free-to-play can be done well, who literally have an allergic reaction to the whole idea of in-app purchases because they harken back to a golden age,” Clark said to Posner. “Let’s make gaming great again. I shouldn’t say that. That’s going to get me into trouble.”

“We used to buy our games upfront. Do you remember that we used to put like a 25 cent, you know, a quarter in arcade machines? For us, it was 50 pence. We would do that every two minutes. And that’s actually part of the golden age a lot of people talk about.”

Touché.

“My point is that we’re mixing the streams,” said Clark.

Wait, was he actually in a “time heist” loop the entire time?

“Why is Ilkka’s letter so important?” he asked Posner. “He’s highlighting that there is some absolutely, really damaging stuff” in the draft DFA legislation.

Ilkka Paananen “has a passion for making great player experiences.”

Agreed. I’m a fifty-something guy who has played Clash of Clans religiously for well over a decade. Ilkka, what have you and your company done? I feel retained.

Left: ChatGPT’s rendition of an ecstatic MGGA gamer. Center: Supercell CEO Ilkka Paananen’s open letter on LinkedIn that laid out the potential dangers for game companies in the EU’s DFA proposal; Right: My current (almost maxed out) village in Supercell’s Clash of Clans.

The DFA, Clark argued, will lead Europeans to have a “subjective framing put onto game design which will be used to punish everybody, to prevent game development and innovation, regardless of its ethical sustainability.”

“I believe we have a duty of care” in the industry, he added. “I think we should exercise that duty of care. What I don’t want is for people to wrongly label things as evil or problematic that aren’t.”

“I’m not going to include microtransactions in an audience target of eight years old personally,” Clark clarified.

“This currency top-up thing is the problem because, if I’ve got to put a real money value to it, and I can earn all of my currency through play for zero, am I actually attributing a cost to your work playing the game? What is the ramification of that? Am I now setting the value of your game account, should you sell it to somebody else?”

Fair questions.

The heat under his collar flushed upward to his face.

“By the way, terms of service generally says ‘You’re not allowed to do this’ but people have and do. If you were to sell your account for a game, have you just made me, as a game developer, commit fraud? Because I’m now valuing your pool of virtual currency at a real money price that is not actually true. You’re making us lie. Now, again, this is my understanding interpretation of what I’ve read. It may not be true.”

I have no idea either: I haven’t read the draft legislation. I suspect, though, that Clark and Paananen…and Supercell’s lawyers…are at least directionally accurate with this “can of worms” view of how this legislation may impact F2P and Live Ops game developers/publishers as currently drafted. If the DFA works similar to GDPR, moreover, the legal change won’t only impact EU-based developers/publishers but all video game purveyors that hawk their wares in the EU.

“There aren’t any game designers in the room and making this legislation,” Clark warned. “We’re seeing a pattern of this, and guess who’s going to pay the price? The smaller indie game developers are going to be the ones caught on this who can’t afford the lawyers.”

So…away put your [tort] weapon?

Oscar Clark: Video Games ≠ Gambling

“FOMO drives demand,” Greg Posner observed in his October 2025 discussion with ARCANIX’s Oscar Clark in regard to F2P game monetization. “You want to drive demand. It’s Halloween. I want to sell the Scream guy and he’s not going to sell in December, right?”

“Let’s take that example,” Clark responded, nodding. “Halloween seasonal update. I’m going to make you a special offer for the Halloween period. I’m gonna make art that I’m only gonna make available during the Halloween period.”

“I’m going to create a sense of scarcity around that, scarcity being another factor of FOMO. And I think it’s not unreasonable for me to have this year’s Halloween things have a time limited capacity to it.”

“When I’m talking about Halloween content,” Clark continued, “I think the kinds of content I want to do for Halloween is going to include free content. And then I’m going to make it available to people who didn’t manage to unlock it for free during play to be able to buy it, after the season has passed.”

“For me, that sounds perfectly reasonable and fair. In fact, as a player, I want that. I want that choice.”

“I’m going to sound like an absolute evil, moustache-twirling, top hat wielding monetization idiot to some people,” continued Clark. “It’s not like that. I want to create delight. I want to create experiences that you value. And if I don’t have scarcity, I’m undermining the value. If I don’t create time-relevant content, I undermine the value. Let’s stop undermining value. Let’s try and make sure we’ve got guardrails of ethics.”

Left: Ghostface from the Scream franchise. Right: ChatGPT’s rendition of a “absolute evil, moustache-twirling, top hat wielding monetization idiot.”

Posner said something about Meta’s Mark Zuckerberg being hauled before Congress every couple of years and having to answer “some of the silliest questions in the world.”

Clark nodded again.

“The games industry is an industry that has spent decades being attacked for existing,” he said. “As was film before it, as was music, you know, Reefer Madness was a massive thing, you know, ‘The films are corrupting our youth.’ I think even books have had this…”

“They’re going to…give people the ability to have ideas. How dare they! Any industry that is trying to introduce thought and innovation, creativity is going to have backlashes.”

“When you have,” Clark added, “the largest form of digital entertainment on the planet, the only one that’s a verb, then no wonder…and if your only parallel in your mind, as somebody who isn’t a gamer, is going to be gambling, there is an assumption that they’re the same vector.”

“One of the reasons why that’s becoming even harder is the World Health Organization making gaming addiction something that’s in the DSM-6” Clark said. “I’m not a psychologist. But that is incredibly controversial because what that is doing…is labeling a behavioral addiction pathway as causal when all of the evidence is [that] it is just one of many pathways, like, a crutch that people who have a behavioral addiction issue happen to have used, as is using social media, as is work-a-holism, as is other forms of addiction, but that are behavioral based.”

The American Psychiatric Association’s Diagnostic and Statistical Manual (DSM) is currently on its fifth version. In it, there’s a condition that’s called Internet Gaming Disorder (IGD). IGD is recommended for further research, along with caffeine use disorder, and some similarly concerning conditions to psychiatrists.

A DSM-6 revision is on the way but it probably won’t be out until 2029 or 2030. What Clark was referring to, apparently, was the process that’s underway to further reconcile the International Classification of Diseases (ICD), which the World Health Organization (WHO) puts together, with the DSM-6. The ICD-11 also includes a gaming disorder (the description is here.) Clark’s point is that if playing a lot of video games is raised to the level of addiction as a hardcore gambling addiction, then legislators around the globe will have more of a basis for cracking down on “excessive” video game playing, especially among minors.

“The difference between gambling and games in terms of addiction is there is a physiological impact, which is causal,” Clark told Posner.

“In a gambling process, the adrenaline response from a gambling process has a causal impact. Now, that’s not me saying it. I took that from the Harvard Medical Review.”

I didn’t track down the specific study but there’s a publication called the Harvard Medical Student Review, and this study may be somewhere on its site.

“The issue we have right now is fundamentally about what’s happening in this industry. And we’re actually being attacked from a whole bunch of sides, not intentionally. I think it’s inadvertently.”

“If you look at the way the Digital Markets Acts are going on,” Clark continued, there’s cause for ongoing concern from that direction as well.

The EU passed the Digital Markets Act (DMA) in 2022. Per the legislation, large digital platforms, aka “gatekeepers,” are required to comply with various obligations and prohibitions, although aspects of the DMA are up in the air and/or working their way through the court system.

“Epic have won their case against Apple in terms of the use of [payment options] outside of a game,” Clark noted. “That’s potentially great. But the opposite seems to be happening in Europe. We don’t know what’s happening there, but let’s think about things like the Online Safety Act in the UK. And I think there’s going to be some Texas regulations [that] do something similar. This is requiring us to have facial recognition or some sort of true identity to ensure that we are over a certain age. Sounds great, doesn’t it?”

The UK’s Online Safety Act passed in late 2023, and was indeed designed to protect children from various online harms and illicit content; service providers have an age-related verification responsibility per those laws. An overview of the Texas legislation in question, which is wrapped up in a court battle too, is here.

“There’s some fantastic stats out there about how badly these facial recognition systems perform and how they will often over and under age people,” Clark told Posner. “We’re not actually making people any safer…[and] we are requiring the developer to hold the data.”

For what it’s worth, facial age estimation via smartphone cameras seems to be getting better. A LinkedIn assessment pointed out last year, for example, that the margin of error for children is generally now ±4 years for the worst-performing algorithms and as little as ±1 year for the best ones.

“My objection is not about wanting to keep the kids safe,” Clark continued. “I want children to be safe. Where the Online Safety Act in the UK came from was an attempt to save the kids from pornography. Sure, okay, that. But do you know how many kids are going to be safe from pornography through this act? None, ‘cause there’s a thing called a VPN.”

“There’s hysteria and a lack of clarity. And do you know what? There are ways that we could have solved that, had there been proper consultation that actually involved people who understood how technology worked.”

“Back to Ilkka’s letter,” Clark said, finally landing his time-travelling plane. “This is what Ilkka is asking for: Let’s have some proper consultation.”

“The irony is the platforms have the capacity to solve it. And what happens in physical retail is [that] the retail store, the point where the transaction is happening…are the people [there] responsible for managing the experience? Guess what? Now we’ve got the storefronts who are taking their 30%, or whatever that number is, not being held accountable for doing that part of the job.”

I presume Clark was thinking about physical stores that have been caught selling cigarettes, liquor, nudie magazines, and lottery tickets to minors.

Clark tied off this piece of the conversation with a bow: “To me, that is absolute hypocrisy.”