IV: Oblivion was re-rated from "T" ("Teen 13+") to M after the ESRB discovered "more detailed descriptions of blood or gore than were considered in the original rating", as well as a locked skin which, if modded, allowed female characters to appear topless. Responding to both the Grand Theft Auto and Elder Scrolls incidents, the ESRB testified before the United States House Energy Subcommittee on Consumer Protection and Commerce that after that point, manufacturers who failed to disclose mature or explicit content would be punished with fines up to $1 million. In September 2006, Senator Sam Brownback introduced the Truth in Video Game Rating Act, which would require the ESRB to access the full content of games before issuing a rating, as opposed to relying on video demonstrations from game companies. Brownback introduced the bill to both the 109th and 110th Congress, and it expired without action at the end of both sessions. Take-Two, Rockstar Games, and the Grand Theft Auto series In June 2006, Take-Two cancelled Snow, a real-time strategy game about illegal drug trade that had been in production at its Frog City Software studio. While the publisher provided no reason for this decision, it was believed that it stemmed from the "increased political pressure" Take-Two was under, partially brought about by the "Hot Coffee" scandal. Rockstar Games released Grand Theft Auto IV, the next game in the Grand Theft Auto series, on 29 April 2008, to critical and commercial acclaim. Some fans believed that the game included an Easter egg referencing Hillary Clinton's involvement in the "Hot Coffee" controversy. In the game, the Statue of Happiness, a Statue of Liberty-type figure, bears a physical resemblance to Clinton holding a steaming cup of coffee in place of a torch, and the game file for the statue is named "stat_hilberty01.wdr". The "Hot Coffee" scandal was mentioned again upon the 2014 release of Grand Theft Auto V, in which players could engage in sexual activity with prostitutes from a first-person perspective. Despite this mechanism, Grand Theft Auto V received an M rating from the ESRB. In February 2020, a modification to Red Dead Redemption 2 was released on Nexus Mods that drew comparisons to "Hot Coffee". In the mod, protagonist Arthur Morgan meets a prostitute in a saloon and takes her upstairs to engage in sexual intercourse. Rockstar Games, who developed the Red Dead series as well as Grand Theft