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About the Claim

What is the claim about?

The claim alleges that since at least 5 June 2018, Valve Corporation has abused its dominant position in the PC gaming market – leading to UK gamers paying more than they should for PC games and add-on game content on Steam, Valve’s popular game distribution platform.

The claim alleges that Valve Corporation is breaching competition law by:

  • Preventing price competition – Valve impose price restrictions which mean that games sold on Steam cannot be offered at lower prices on other platforms, making it harder for rivals to compete and keeping prices high.
  • Controlling pricing and release timing for in-game content – Developers are restricted from offering add-on content at lower prices or earlier on other platforms, limiting consumer choice and value.
  • Tying in-game purchases to Steam – Once you buy a game on Steam, you are locked into buying all add-ons there too, allowing Valve to collect a commission on every transaction.
  • Charging high commissions to developers – These extra costs are often passed on to consumers through higher game and add-on prices.

We allege that this behaviour has harmed competition and led to inflated prices for UK gamers. Under UK competition law, companies with a dominant market position are not allowed to block fair competition or control pricing in this way.

This claim is about making sure powerful companies like Valve play fair, so that gamers benefit from lower prices, better platforms, and real choice. Read more about the claim and view our key documents.

The claim is against Valve Corporation. Valve owns Steam – the largest digital distribution platform for PC games.

We believe that Valve has abused its dominant position in the PC gaming market, in breach of UK competition law. This alleged misconduct falls into three main areas:

  1. Blocking cheaper prices on other platforms (Price parity obligation clauses): We say that Valve imposes price parity clauses that prevent game developers from offering lower prices for PC games and add-on content on rival platforms. These price parity clauses apply to all games listed on Steam, not only those distributed via Steam Keys. As a result, other platforms cannot offer better deals, limiting consumer choice and keeping prices higher across the board. This harms competition in the market and stops other platforms from improving their services.
  2. Forcing gamers to buy add-ons through Steam (Tying): We say that Valve imposes restrictions that add-on content (such as downloadable extras) be bought only through Steam if the game was purchased there. This is anticompetitive as these conditions are unilaterally imposed without publisher choice. We say this is unfair because add-ons are a separate product – and gamers might find them cheaper elsewhere if given the choice. This restriction gives Valve more control, cuts out competition, and forces consumers to pay commissions that Valve collects.
  3. Charging excessive fees (Excessive pricing): Valve charges developers a commission of up to 30% on every sale. Although this fee is charged to publishers, it gets passed on to consumers in the form of higher prices of games and add-on content on Steam.

We believe this conduct has caused UK gamers to pay more than they should, while also harming innovation and competition in the market. You can read more about the claim in the Summary Claim Form here.

This collective legal action is seeking compensation for PC gamers who may have overpaid for PC games and add-on content as a result of Valve Corporation’s actions.

The claim is intended to promote fair competition and fair pricing in the digital gaming industry. It aims to ensure that dominant companies like Valve do not stifle competition in the market. When competition is fair, PC gamers benefit from better services and prices.

Vicki Shotbolt is seeking financial compensation for PC gamers who were affected by inflated prices they have paid due to Valve’s alleged anti-competitive conduct.

In addition to compensation, the Tribunal may require Valve to change how it operates its Steam platform or implement other remedies it deems appropriate. These outcomes aim to improve fairness in the digital gaming market.

The estimated compensation ranges from around £22 to £44 per person, depending on how much an individual has spent on Steam or other PC gaming platforms for PC games and add-on content. Additional compensation may be available for those based in Scotland. While there is no guarantee that compensation will be awarded, there is no cost to individuals at any point throughout the claim.

The total estimated compensation is £656 million, covering approximately 14 million PC gamers. Collective claims like this help consumers seek redress against large companies when individual losses may seem small but add up significantly across the group.

If the claim is successful, compensation will be distributed to those affected by Valve Corporation’s anti-competitive behaviour.

Claims of this size can take several years to resolve.

The collective proceedings claim against Valve was filed at The Competition Appeal Tribunal (‘Tribunal’) on 5 June 2024. This marks the first stage of the legal process. The Tribunal will now decide whether to certify the claim – that is, whether it can proceed as a collective action and whether Vicki Shotbolt is a suitable representative for affected gamers.

If the claim is certified, the Tribunal will issue a Collective Proceedings Order, allowing the case to move to trial. At trial, the Tribunal will hear evidence from both sides (the claimant and defendant) and decide whether to award damages to those affected.

At any stage, the parties may agree to an out-of-court settlement. However, any proposed settlement must be reviewed and approved by the Tribunal.

This claim is an opt-out proceedings. This means you are automatically included in the Proposed Class if you have paid for PC games or add-on content from 5 June 2018.

Sign up to stay updated as the claim progresses.

About the class

Vicki Shotbolt is seeking compensation for everyone who paid for PC games or add-on content in the UK from 5 June 2018. For those based in Scotland, this date may extend further back.

The group of people who have been affected are known as the Class – find out more about how the Proposed Class of affected gamers is defined.

The proposed class of claimants for the purpose of the Claim (known as the “Proposed Class” and “Proposed Class Members” or “PCMs”) consists of:

All Persons who, during the Relevant Period, made one or more payments for the purpose of purchasing:

  1. PC Games;
  2. Add-on content for PC Games, including subscription payments for PC Games and/or add-in content (collectively “Relevant Purchases”).

For the purposes of this definition of the Proposed Class (“Class Definition”):

  1. “Persons” means, in respect of Relevant Purchases, the person who was licensed to use the acquired content, typically the account holder.
  2. “Class Period” means the period up to the date of the Collective Proceedings Order in these proceedings: (i) from 4 June 2018, in relation to members of the Class domiciled in England, Wales and Northern Ireland; and (ii) from 1 January 2010 in relation to members of the Class domiciled in Scotland.
  3. “PC Games” means video games designed to be played on PCs (i.e. personal computers), as opposed to on other types of hardware such as consoles or mobiles, including PCs built by Apple and/or using a Mac operating system.
  4. “Add-on Content” means content that can be added-on to PC Games that is purchased after the initial acquisition of the game, sometimes referred to as Downloadable Content (“DLC”), and includes content acquired through Microtransactions completed during gameplay.

All Persons who fall within the definition of the Proposed Class and, on a date of domicile to be determined by the Tribunal, are:

  1. domiciled in the UK, are proposed to be included in the Proposed Class; and
  2. not domiciled in the UK, are proposed to be permitted to opt-in to the proceedings.

In respect of any person who meets the Class Definition but has subsequently died, the Class will include their legal representative, a successor or assignee.

You need to have been over 13 years old when the claim was filed on 5 June 2024 to be included in the Proposed Class. This is because it will be the account holder who made the purchase who will be the member of the Proposed Class. This means that you can be part of the claim on your own behalf if you are 13 or over, as this is the minimum age to sign up to a Steam (or other gaming) account.

If you are younger than 13 and playing PC games, then it will be the account holder that will be included in the Proposed Class, who may be a parent or guardian.

If you are over 13 but under 18 and purchased games or add-on content through your own account, then you will be in the Proposed Class (even if the purchase was paid for by card of a parent or guardian) but we will ask you for the details of your parent or guardian for any update emails we might send.

You do not need to do anything. Proposed Class Members, (see the Proposed Class definition above), will automatically be included in the claim. You can sign up for updates as which we will provide as the claim progresses.

If you don’t want to be a part of the claim, you will need to opt-out. You will be given the chance to opt-out if the claim is certified. We will publish an option for doing this on this website as soon as the claim reaches this stage.

If you are within the Proposed Class, you will be included in the claim, even if you are no longer a Steam user.

There is no risk for Proposed Class Members.

You will not have to pay anything at any stage in the claim, even if it is unsuccessful. You will not face any personal risk in relation to these proceedings.

For more detail on who is paying for the claim, see Who is funding the claim?

About the legal framework

Competition law seeks to curb practices that undermine or restrict competition to the detriment of consumers. Competition law infringements include abuses of dominant market positions by companies.

Collective proceedings can only be brought in the Competition Appeal Tribunal, which specialises in resolving competition law disputes.

Collective proceedings are when a group of people affected by the same issue are represented by a single person to bring a claim. It provides important access to justice in circumstances where they might not otherwise be able to bring a claim.

Consumers can use collective proceedings to hold large companies to account. Collective actions need class representatives and the proposed class representative in this claim is Vicki Shotbolt.

The group of claimants is referred to as a ‘class’ and each claimant in the group is referred to as a ‘class member’.

The first step in bringing collective proceedings is to apply for authorisation from the Competition Appeal Tribunal. This is achieved by filing an application for a Collective Proceedings Order. This Order of the Tribunal authorises the proposed class representative to act on behalf of the class and certifies the individual claims for inclusion in the collective proceedings. Vicki Shotbolt filed this application for Collective Proceedings on 5 June 2024.

Collective proceedings are categorised as ‘opt-in’ or ‘opt-out’, according to the way in which claimants are admitted to the class(es). Opt-in collective proceedings require class members to sign up to participate in the claim, while opt-out proceedings include everyone who falls within the class definition approved by the Tribunal in the claim, allowing individuals who prefer not to be included in the proceedings to opt out.

This claim is brought on an opt-out basis.

This is one of the earliest procedural milestones of a collective proceeding. When the Competition Appeal Tribunal ‘certifies’ a collective proceeding, it authorises the class representative to act for the class members and grants the class representative their application for a Collective Proceedings Order. This means the claim can proceed to trial, unless it is settled beforehand.

A case management conference (also referred to as a CMC) is a step in litigation used by the Competition Appeal Tribunal to give directions as to the way the case is to be conducted and to set up the future timetable.

About the team

Vicki is a leading campaigner for children’s digital rights. She is the founder and CEO of Parent Zone, which specialises in understanding the impact of online services/digital technologies on families and children.

Parent Zone’s work includes advising on government policy and commissioning independently funded research to inform its work with families and advocacy activity. Vicki is dedicated to working to improve the lives of children in an increasingly digital world.

Vicki is seeking permission, via Vicki Shotbolt Class Representative Limited, to bring this action against Valve Corporation because she believes that users of Steam have been treated unfairly and she wants to make Valve Corporation compensate consumers.

Vicki Shotbolt, via Vicki Shotbolt Class Representative Limited, is seeking permission from the Competition Appeal Tribunal to act as the class representative in the claim.

A class representative is a person who represents those who are in the class. The class representative conducts the collective proceedings against the defendants on behalf of all class members, except those who opt out, and instructs the legal team.

A class representative is responsible for communicating with and issuing formal notices to the class members. We intend to facilitate this via updates and announcements posted on this website, email correspondence and written notices.

Until permission is granted by the Tribunal, Vicki Shotbolt Class Representative Limited is known as the ‘Proposed Class Representative’.

Sign up if you would like to receive updates relating to this claim.

Milberg London LLP is a leading consumer advocacy law firm. It is highly experienced in handling complex collective action claims.

Milberg has worked on some of the biggest consumer cases to be heard before UK courts, including an up to £5 billion consumer claim against Sony Playstation which alleges the popular gaming platform has forced up prices for around 8.9 million UK consumers.

Funding the claim

No, there will be nothing to pay at any point.

Vicki has secured funding to cover the costs of the claim, which means you do not pay anything to be part of the claim and will not have to at any point. See Who is funding the claim.

Vicki Shotbolt has secured litigation funding from Bench Walk Advisors.

The legal team at Milberg are working on a conditional fee agreement (‘CFA’), which means only part of their normal fees are paid (by Bench Walk Advisors) during the claim. The remaining fees are only paid if the claim is successful. This is common where a class representative is not able to fund a claim of this size and public importance on their own.

If the claim is successful, the funder and legal team will receive a fee or uplift (which is the difference between the discounted rate charged during the claim and the normal chargeable fees) in exchange for taking on the risks of the claim. This is common in all cases funded by third-party funders and via CFAs. The fee is calculated depending on the stage the case has reached and how much the class representative has spent.

The Tribunal oversees the amount of the success fees paid to lawyers and funders and the distribution of any compensation to the Class Members.

If the claim is not successful, the funder will not receive anything, and the legal team will only receive its discounted fees for the work undertaken. After-the-event (‘ATE’) insurance has been secured to protect against the risk of having to pay the Defendants’ costs if the claim is not successful. ATE insurance is a specific type of insurance to cover the risk in litigation of reasonably incurred adverse legal costs.

The Tribunal has wide powers to order the payment of fees, including the uplift, or other legal expenses or disbursements (when not recovered from the Defendants), including the success fee and funder’s fee from an award of damages, either before or after distribution to the Class Members.

No.

This type of litigation is essential to help address the imbalance of power that hugely favours big corporations to the detriment of consumers. Big businesses like Valve Corporation should not be able to get away with unlawful behaviour simply because the legal system is currently stacked in their favour.

For most people the idea of taking on big business is quite terrifying (if possible at all) and potentially ruinous. Collective Proceedings enable claims like this one to be brought on behalf of millions of consumers who could not bring claims alone. This was why the collective actions regime in the Competition Appeal Tribunal was established by the government in 2015, recognising that there were huge challenges with access to justice for consumers.