Circa’s Barbie Activation Raises Qs Around ‘Nostalgia’ Marketing and Responsible Gambling Risk

For most of last week, Circa Resort and Casino glowed Barbie-pink as the adult-only casino resort became the Barbie movie’s “official” Vegas hotspot.

The activation, which ran from July 18 to 23, saw Circa’s Stadium Swim transform into a poolside homage to Barbie Land in celebration of the now-hit movie’s July 21 release.

barbie turns circa resort casino pink

The casino resorts’ age limits notwithstanding, the Circa/Barbie marketing connection raises questions about what’s appropriate when mixing gambling and children’s toys.

Keith S. Whyte, the executive director of the National Council on Problem Gambling (NCPG), told Bonus over the phone last week:

We definitely have some concerns around Barbie and casino activations.

But the concern, he added, isn’t exactly new:

There’s been a long history of the gambling industry using products or themes or images that may appeal to children.

Lotteries Often Tap Themes With Youth Appeal

Until recently, explained Whyte, the concern around cross-marketing of gambling and children’s content focused mainly on lottery products.

Lotteries have offered content based on titles initially intended for children for years.

The lotto industry, he said to Bonus:

Has long-licensed themes that were originally associated with children’s TV or movies. The Addams Family, Monopoly, and Willy Wonka are probably some of the more recent examples.

The NCPG, he added, has previously expressed its concerns over appealing to youth.

They’ve also had to contact non-gambling corporations over questionable gambling-themed promotions. For example, some years back, McDonald’s and Nintendo teamed up to include a Mario-themed slot machine in Happy Meals.

On the gambling side of things, Whyte said the industry’s defense of such choices is almost always “nostalgia.”

Generally, something is nostalgic if it has been out for 20-plus years, even if based on children’s themes. And according to the industry, nostalgic slot machine titles, themes, and games are perfectly appropriate, he said.

Whyte added that many gambling marketers use age-restricted gambling access as reasoning that nostalgic themes are appropriate: Kids won’t see it.

Circa Says Barbie Marketing Celebrates Nostalgic Brand

Still, Whyte was clear he couldn’t speak on behalf of the industry. Instead, he said, he was only reporting his experience.

In addition to the NCPG, Bonus reached out to Circa, the American Gaming Association (AGA), the Responsible Gambling Council (RGC), Warner Brothers Pictures (WBP), and Mattel for this story.

As of publication, Bonus hasn’t received a response from the RGC, WBP, or Mattel.

While the AGA did respond, the organization declined to comment.

However, a statement shared by a Circa Resort and Casino spokesperson echoed Whyte’s observations:

Circa Resort & Casino is a 21+ resort/casino, and as such, the theme and/or partnership with Warner Bros. showcasing some Barbie attributes at Stadium Swim® is appropriate. All efforts are targeted specifically to adults who grew up with Barbie themselves and now are enjoying the celebration of this nostalgic brand.

Nostalgic Themes Boost Problem Gambling Concerns

Notably, the NCPG hasn’t argued that nostalgic themes are necessarily off-limits. Instead, it’s called for additional focus on responsible gambling offsets.

Whyte told Bonus:

We’re not saying they’re always inappropriate, but we are saying there’s an increased responsible gambling concern. If the theme used to appeal to kids, it probably still does. And maybe you need to take that into account.

That brings us to Barbie, a doll originally and primarily marketed to children, he said.

Whyte said to Bonus:

In this case, with Circa, you run the risk that you’re going to attract or appeal to people who are underage and that you’re associating your brand with a child’s toy.

We understand that it may also appeal to adults. And we’re not regulators, but we would say, in the case of Circa, we hope they increase their underage gambling prevention efforts.

Perhaps they would partner with a community-based organization like the Nevada Council on Problem Gambling to try and counterbalance the impact of having associated their Casino with a toy that is, frankly, primarily intended for young children.

AGA RG Code of Conduct Lacks Needed Teeth

While the AGA had little to say to Bonus about Circa’s Barbie activation, the organization’s Responsible Gaming Code of Conduct lives online.

Notably, the section related to responsible advertising calls out marketing that appeals to youth.

Specifically, the AGA code says members’ casino gambling, including sports betting and online gaming advertising and marketing, will not:

  • Contain images, symbols, celebrity/entertainer endorsements, and/or language designed to appeal specifically to children and minors
  • Feature anyone who is or appears to be below the legal age to participate in gambling or sports betting activity or imply that underage persons engage in casino gambling or sports betting

That said, the code also differentiates between members’ advertising of gambling activities and the marketing of casino-related hotels and properties:

This Code applies to AGA member companies’ advertising and marketing of casino gambling, including sports betting and online gaming. It does not pertain to advertising and marketing that is primarily of hotels, restaurants, and entertainment that may be associated with or operated or promoted by casinos.

Sports Wagering Marketing Code Could Offer More

Viewed in that light, it’s unlikely AGA’s general code of conduct applies to Circa’s Barbie marketing.

However, the AGA also released its Responsible Marketing Code for Sports Wagering in March of this year. Circa, of course, operates a sportsbook along with the resort and casino at this Vegas site. And Stadium Swim features a 40-foot screen broadcasting live sports and betting lines.

Specifically, the first three points from Section One of the code, Respecting the Legal Age for Sports Wagering, include:

  • No sports betting message should be designed to appeal primarily to those below 21 – the prevailing legal age for sports wagering
  • Advertising should not depict cartoon characters or feature entertainers, athletes, influencers, or music that appeal primarily to audiences below the age of 21
  • Models, actors, influencers, athletes, and entertainers appearing in advertising should be a minimum of 21 years old, substantiated by proper identification

However, whether AGA would consider Circa’s Barbie takeover an infraction of the sports betting marketing code is unclear.

Also, as Whyte pointed out to Bonus, events like this are hardly gambling’s most significant issue:

This is not the biggest problem in the gambling world … I mean, in terms of what the National Council on Problem Gambling is focused on. There are a lot more fundamental and serious things that we’re doing.  I’m not going to over-dramatize it.

Still, Whyte thinks Circa has a responsibility to up its RG game:

If they’re going to run a promotion like this, they should redouble their responsible gambling efforts; especially those oriented towards preventing underage individuals.

Doing this promotion with its known appeal to children means they should redouble those efforts.

Update (07/26): The AGA has clarified that its Code is meant to reflect commitments made by operators independently. It does not seek to determine whether or not any given member is complying with its specifications.

Not Scared of Risks, Barbie’s Never Been A Gambler

Interestingly, since her creation in 1959, Barbie, whose slogan is, “You can be anything,” worked over 250 jobs. Notably, she’s never been a card dealer, poker pro, or gambler of any flavor.

She has, however, been the US President, a beekeeper, an MLB player, a pilot, chef, lounge singer, showgirl, rapper, and much more.

Ironically, while the doll is 64, Barbie, the woman, is reportedly frozen at 19 — ever full of possibility.

Amusingly, that means that if Barbie came to life as she did in the movie, she’d be too young to celebrate Barbenheimer weekend poolside at Circa.

As a result, said Whyte, Barbie marketing will likely be a topic of conversation at NCPG’s national conference later this week.

He told Bonus:

They’re deliberately associating their brand with a toy that is primarily for young children. That’s an interesting approach and one that carries reputational and responsible gambling risks.

All photo credits to Black Raven.

About the Author

Robyn McNeil

Robyn McNeil

Robyn McNeil (she/they) is a Nova Scotia-based writer and editor, and a lead writer at Bonus. Here she focuses on news relevant to online casinos, while specializing in responsible gambling coverage, legislative developments, gambling regulations, and industry-related legal fights.
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