other violent media has been linked to aggressive behavior." The proposed legislation was referred to the Subcommittee on Commerce, Trade and Consumer Protection. On 24 January 2011, Joe Baca reintroduced the Video game health labelling act as H.R. 400 of the 112th Congress. The bill was once again passed onto the subcommittee. On 27 June 2011, the Supreme Court of the United States ruled on Brown v. Entertainment Merchants Association. Video games were protected speech under the First Amendment. The case centered on a California law that sought to restrict sales of violent video games to minors. The video game industry, led by the Entertainment Merchants Association and the Entertainment Software Association, successfully obtained an injunction on the bill, believing that the definition of violence as stated in the California law was too vague and would not treat video games as protected speech. This opinion was upheld in lower courts, and supported by the Supreme Court's decision. The majority of the justices did not consider the studies brought to their attention as convincing evidence of harm, and stated that they could not create a new class of restricted speech that was not applied to other forms of media. However, Justice Breyer's minority decision found the evidence more convincing. Deana Pollard Sacks, Brad Bushman, and Craig A. Anderson objected to the ruling, claiming that the thirteen experts who authored the Statement on Video Game Violence on the Brown side were considerably more academically merited, and had on average authored over 28 times as many peer-reviewed journal articles about aggression/violence based on original empirical research as the signatories supporting the EMA, whereas the over 100 signatories supporting Brown had on average authored over 14 times as many. Richard Hall, Ryan Hall, and Terri Day replied: "It is not surprising that Anderson and Bushman found their own qualifications and the qualifications of those who agree with them to be superior to the qualifications of those who disagree with them", and claimed that they might have used methodology which have undercounted contributions of some scholars. On 3 April 2013, Dianne Feinstein, a Californian senator and Democrat, spoke in San Francisco to a group of 500 constituents about gun violence. She said video games have "a very negative role for young people, and the industry ought to take note of that" and that Congress might have to step in if the video games industry did