impact the gaming industry. The VGV was launched in 2006 by the ESA, and uses social media sites like Facebook and Twitter to inform members of allies and opponents. In 2013, the ESA spent over US$3.9 Million on lobbying, including but not limited to against VVG legislation. This included opposing a bipartisan federal bill that would direct the National Academy of Sciences to study the effects of all forms of violent media. Such bills themselves had come under criticisms from some scholars for pressuring scientists to find specific outcomes rather than studying the issues neutrally US government legislation The regulation of video games have been historically supported by politicians such as Joe Lieberman and Hillary Clinton, who have pushed legislation for regulating video games. No video game console manufacturer has allowed any game marked AO to be published in North America; however, the PC gaming service Steam has allowed AO titles such as Hatred to be published on its platform. No major retailers are willing to sell AO-rated games. However, Grand Theft Auto: San Andreas was rated AO after the presence of the Hot Coffee add-on became evident. The add-on was later removed and the game rated M. In the 109th Congress and 110th Congress, the Video Games Enforcement Act was introduced to the US House of Representatives. The act required an identification check for the purchase of M and AO rated games. The bill and others like it did not succeed because of likely First Amendment violations. Although no law mandates identification checking for games with adult content, a 2008 survey by the Federal Trade Commission showed that video game retailers have voluntarily increased ID verification for M- and AO-rated games, and sales of those games to underage potential buyers decreased from 83% in 2000 to 20% in 2008. A further survey in April 2011, found that video game retailers continued to enforce the ratings by allowing only 13% of underage teenage shoppers to buy M-rated video games, a statistically significant decrease from the 20% purchase rate in 2009. On 7 January 2009, Joe Baca, representative of California's 43rd District, introduced H.R. 231, the Video game health labelling act. This bill called for a label to be placed in a "clear and conspicuous location on the packaging" on all video games with an ESRB rating of T (Teen) or higher stating, "WARNING: Excessive exposure to violent video games and