Ad Standards upholds complaints against Brisbane strip club mobile ads

Ad Standards has upheld complaints against sexually explicit road-side strip club advertising just 500m from a local primary school. 

The three-panelled trailer showed a fully naked woman against a bright pink background advertising 'Dollhouse Showgirls.' Commuters and children walking and riding to and from school were exposed to porn-themed imagery on a daily basis. The bright pink panels and the words "Dollhouse Showgirls" had the dual impact of drawing children's attention to the ad. We heard from one mother who said her small child had asked about 'the dollhouse.'

While acknowledging that Ad Standards upheld the complaint, it must be noted that the reasoning provided in the determination still raises questions about the competence of the regulatory body to deal with complaints.

Ad Standards Case Report

The Description

The Ad Standards determination begins with an inaccurate description of the advertisement (emphasis ours).

Both side panels feature an image of a naked woman from the side. Her hands are cupping her breasts and her legs are bent in a way that obscures her genitals. Superimposed over the image is a ticket with the words 'free entry' and details of the business.

The rear panel of the advertisement features a naked woman with her long hair obscuring her breasts and her arm placed in a way which obscures her genitals.

The woman's genitals are exposed on the two side panels of the trailer, a fact later acknowledged in the determination. 

The determination

Excerpts from the determination and our response:

"The Panel considered whether the advertisement was in breach of Section 2.2 of the Code. Section 2.2 of the Code states: “Advertising or marketing communications should not employ sexual appeal in a manner which is exploitative or degrading of any individual or group of people.”

The Panel considered that the depiction of a naked woman in connection to a gentleman’s club is one which most people would consider to contain sexual appeal.

The Panel noted that this is a legal business and although some members of the community dislike the fact that women in the business are paid for adult entertainment services, this does not mean that the advertisement is exploitative."

Response:

The implication here is that people made complaints because they "dislike the fact that women in the business are paid for adult entertainment purposes." This is a condescending statement completely irrelevant to the complaint about a sex trade advertisement positioned 500m from a school, or parked in a suburban street. 

What makes the advertisement exploitative is that it broadcasts a naked woman to an all ages audience including children in order to market their sex trade venue.

"The Panel considered that there was a focus on the woman’s body in the advertisement, however noted that the advertised product is a gentleman’s club which features scantily clad and naked women as part of its service. The Panel considered that the images used in the advertisement are clearly related to the product being advertised."

Response:

This is outdoor advertising for a strip club featuring a completely naked woman. When not parked in suburban streets, it is driving through suburbs in and around Brisbane. Why does it matter that the image of a naked woman advertising an adults only sex trade venue is relevant to the "product" being advertised?

"The Panel considered that the advertisement depicted the woman in a manner which is indicative of her normal employment and did not depict the woman, or women in general, in a way which lowered women in character or quality."

"The panel determined that the advertisement did not employ sexual appeal in a manner which is exploitative or degrading of any individual or group of people, and did not breach Section 2.2 of the Code."

Response:

Ad Standards has made this determination based on falsehoods. The claim that the advertisement "did not depict the woman, or women in general, in a way which lowered women in character or quality" flies in the face of decades of research on the representation of women and girls in media, advertising and pop culture. 

The truth is women are harmed by sexual objectification. This is not new information.

A meta-analysis of 109 publications containing 135 studies found:

“regular…exposure to [sexually objectifying] content are directly associated with a range of consequences, including higher levels of body dissatisfaction, greater self-objectification, greater support of sexist beliefs and of adversarial sexual beliefs, and greater tolerance of sexual violence toward women. Moreover, experimental exposure to this content leads both women and men to have a diminished view of women’s competence, morality, and humanity.” (Media and Sexualization: State of Empirical Research, 1995–2015)

Next:

"The panel considered whether the advertisement was in breach of Section 2.4 of the Code. Section 2.4 of the Code states: “Advertising or Marketing Communications shall treat sex, sexuality and nudity with sensitivity to the relevant audience”.

The panel ultimately determined that the advertisement did breach section 2.4 of the code and upheld the complaints on this basis.

It is in this section the panel admits the woman's mons pubis is visible (although they refer to it as the 'pubic mound'), contrary to the description they provided earlier in their own document. However the panel appears to lack understanding of women's anatomy and the fact that the mons pubis is part of a woman's genitalia.

It is notable that ad industry self-regulation is now at a point where we are discussing the visibility or not of women's genitalia in advertising and that these decisions are inconsistent. See: The advertising body tasked with considering community complaints now won’t even look at them 

Dollhouse Showgirls Responded

The Advertisers response contains a number of inconsistencies and concludes with a threat of legal action against complainants. We include an excerpt of their response here (images ours):

"Our client notes that Dollhouse Showgirls is a legal business and although people may dislike the fact that women in the business are paid for adult entertainment services,..." 

"Our client submits that the woman depicted in the advertisement is in a pose relevant to the business and product being promoted..."

"...Our client denies that the images contain sex or sexuality as the defined in the Macquarie Dictionary.

Response:

The strip club claims women in the business are paid for adult entertainment services and the woman is "in a pose relevant to the business and product being promoted." 

That "business" and that "product" requires an adult entertainment permit. The business provides "sexually explicit activities" such as "strip teases" and "exotic nude dancing." It doesn't make sense to use a definition from the Macquarie Dictionary when their own adult entertainment permit makes it clear that if the "woman depicted in the advertisement is in a pose relevant to the business and product promoted" then the image, by definition, must "contain sex or sexuality." 

"While the images do contain partial nudity the depiction of the woman is relevant to the business’s services being promoted and is treated with sensitivity to the relevant audience. The level of nudity in the advertisement is not excessive ...


...and the woman is not posed in an overtly sexual way."

Accordingly, our client disputes that the images would attract the attention of young children and say that young children who view the advertisement would see images of a model and would not understand the nature of the business. The images are of a fictious [sic] nature and styled in a way that does not depict sex or sexuality.


"Styled in a way that does not depict sex or sexuality" - but used as shop front advertising for a strip club. 

The advertiser concludes by threatening legal action against the complainant.

"We note the complainant has used the term “sex trade advertising” in the complaint. We advise that this term is defamatory to our client and should the complainant continue to make defamatory imputations on social media our client reserves their rights under the Defamation Act 2005."

Read the full determination against Dollhouse Showgirls' sex trade advertising here:

Thank you to everyone who spoke out against this ad, including phoning the council and contacting Liquor Licensing. Your voice makes a difference.

See also: 

WIN! [UPDATED] Just 500m from a public Primary School: strip club's public porn

25 Reasons Why Ad Industry Self-Regulation is a Disaster

CSR begins with men growing a conscience


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