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From their humble origins in the 1950s, video games have aggressively grown both commercially and artistically as a medium. Even the industry’s critics cannot ignore that its global gross revenue in 2021 exceeded the combined totals of the film and recorded music industries. In spite of the massive external economic benefits this industry generates, many vocal opponents still remain to the U.S. Supreme Court decision extending video games unqualified First Amendment protection, Brown v. Entertainment Merchants Association, 564 U.S. 786 (2011).