By Remicard Sereme, second-year student in the Economic Law master,
Law’s power, like its meanings, is all over: not only in formal venues, such as courtrooms, legislatures, and government agencies, but also in everyday social practices.
Richard K. Sherwin, Law in Popular Culture
The law and literature movement emerged in American law schools in the 1980’s. It was spearheaded by the publication of James Boyd White’s book The Legal Imagination, in which the well-known American law professor recognized the convergence of the fields of law and literature and advocated for the introduction of the study of literature into legal education. Boyd White notably mentions in this book the idea of “the lawyer’s art” (Boyd White, 1973) and a conception of the lawyer as, first and foremost, a writer through the characterization of “the writer who is a lawyer” (Boyd White, 1973). This movement was born as a response to the proclaimed inadequacies of legal education and the perceived limitations in legal analysis. Throughout the years, it has been presented, notably by the American lawyer Robert Weisberg, as having two parts: law-in-literature and law-as-literature. Weisberg defines the former as “involv[ing] the appearance of legal themes or the depiction of legal actors or processes in fiction or drama” (Weisberg, 1988) and the latter as “involv[ing] the parsing of such legal texts as statutes, constitutions, judicial opinions, and certain classic scholarly treatises as if they were literary works” (Weisberg, 1988). Although the movement originally focused on literature in the traditional sense, i.e as a “body of written works […] distinguished by the intentions of their authors and the perceived aesthetic excellence of their execution”, it has now evolved beyond literature. Scholars like Richard Sherwin have expanded this enquiry on the meaning of law in literature to law and its representation in popular culture. Sherwin, notably, argues that “people absorb a broad array of stories and images about the law, lawyers, and the legal system from books, newspapers, television, news programs, documentaries, docudramas and feature films. We carry these stories and images in our heads wherever we go, including voting booths and jury rooms, where legal meanings – popular, formal, and mixture of the two – take effect” (Sherwin, 2004).
I wish to inscribe this essay within the law and popular culture enquiry by taking an interest in the portrayal of law in video games. More specifically, I will focus on international humanitarian law (IHL), also referred to as the law of war or the international law of armed conflict, in first-person shooter video games like Call of Duty, Arma or Battlefield, which depict combat situations in contemporary war zones. I believe that this enquiry is especially important and relevant in the context of the ongoing war in Ukraine which has given rise to many issues of violations of international humanitarian law since the beginning of the armed conflict in February 2022.
I will start by explaining why I consider video games an interesting form of “literature” to explore in the context of the law and literature movement (I) and then, analyze the imagery of international humanitarian law in first-person shooter video games portraying realistic combat situations and its influence on the perception of the legal framework of wars (II). Finally, I will explore the ways in which international humanitarian law and these first-person shooter video games have come to influence each other in recent years (III).
Video Games: A prime space for meaning
Considering the important space that video games occupy in popular culture and the fact that they are filled with legal imagery (A), I believe that video games are an interesting medium to explore in the context of the law and literature movement because they can be viewed as a rich post-structural space for meaning (B).
Video Games in Popular Culture
Popular culture (“Pop Culture”) is commonly understood as a “set of practices, beliefs, and objects that embody the most broadly shared meanings of a social system. It includes media objects, entertainment and leisure, fashion and trends, and linguistic conventions, among other things”. Video games, undoubtedly, occupy an important space within pop culture. Indeed, since the release of the first-ever commercial arcade game, Computer Space, in 1971, the video game industry has taken the world by storm and grown exponentially. Nowadays, more than 2.5 billion people worldwide play video games and the global gaming market is set to reach $256.97 billion by 2025. It is one of the most popular and most lucrative entertainment medium in the world notably because of the variety of genres and themes that it encompasses. From e-sport games to shooter games, passing by survival horror role play games, there’s a video game for everybody.
Stories and images about the law are regularly included within these games and, in turn, influence their audience’s legal consciousness. For example, in Detroit: Become Human, the player is immersed in a futuristic Detroit, United States, in 2038 in which technology has evolved to a point where human-like androids are everywhere. They speak, move, and behave like human beings but are only machines whose main purpose is to serve humans. The player gets to play three distinct androids and see a world at the brink of chaos through their eyes. Although not phrased in legal terms, the main interrogation of the game centers around the concept of personhood, and by extension legal personhood. It encourages players to think about what makes us human and thus worthy of having rights and being protected by the legal system.
In Law in Popular Culture, Sherwin affirms that “In the age of images, legal reality can no longer be properly understood, or assessed, apart from what appears on the screen” (Sherwin, 2004). Furthermore, he argues that image-based entertainments are all the more persuasive because “they seem to simulate reality more thoroughly, engulfing the spectator (or, in the case of interactive computer and video games […] the participant) in vivid, lifelike sensations. To the extent that persuasion works through emotions as well as reason, images persuade more effectively than words alone” (Sherwin, 2004). Contrary to images and films where the spectator has a passive role, video games require players to make active decisions, such as to use or refrain from using force in first-person shooter video games mimicking combat situations. This distinctive characteristic of video games can be particularly central in shaping legal consciousness as the player interact directly with imageries of the law and legal institutions.
Video Games as the ultimate post-structural space for meaning
Post-structuralism is a way of theorizing which emerged, predominantly in France, in the 1950’s. Rooted in structuralism, a school of thought in the 19th-20th century which affirmed that “a language is a self-contained relational structure, the elements of which derive their existence and their value from their distribution and oppositions in texts or discourse”, post-structuralism represents a retrospective critique of certain structuralist commitments, such as the claim of culturally independent meaning. Whereas structuralist thinking conceived of a text as a form which carries a content with a specific meaning, post-structuralist thinkers, like Roland Barthes and Jacques Derrida, affirmed that there is no difference between meaning and text and that there is no context outside the text. In his famous essay The Death of the Author, Barthes affirmed that “a text is not a line of words releasing a single “theoretical” meaning […] but a multi-dimensional space in which a variety of writings, none of them original, blend and clash” (Barthes, 1967) and that “to give a text an author is to impose a limit on that text, to furnish it with a final signified, to close the writing” (Barthes, 1967). In other words, once written, a text takes up a life of its own and doesn’t have one “true” meaning to be found at its origins, in the figure of the author. The text’s unity lies in its destination, in the space of the reader. Simply put, texts don’t carry any inner truth. They are simply a space for us to interpret meaning.
In the same way, video games don’t carry any inner truth. They are essentially a narrative structure thrown at the players who get to make the story and find meaning as they go along. For example, in Elden Ring, the most popular game of the year, the player is immersed in a fantasy world, called the Lands Between, with the sole instruction to become the Elden Lord. No guidance is given on how to achieve that task or the reason why one should become an Elden Lord. Players can also decide to not heed the call and simply explore the land to meet friends and battle foes. It is up to them to decide the path that they wish to follow and there isn’t one pre-decided ending but multiple ones depending on what one discovers along the journey.
Therefore, it can be said that video games are a prime space for meaning in which it is particularly interesting to explore the images of law, international law and international institutions conveyed to players. In the next part, I am going to focus specifically on the images of international humanitarian law conveyed in first-person shooter video games depicting armed conflicts.
International Humanitarian Law in First-Person Shooter Video Games
Nowadays, war has never been as close and safe for the casual observer as we get access to war-footages from news, social media, etc. At the same time, technology allows entertainment to imitate life more and more realistically, making it possible for the video game industry to offer players an immersive experience into increasingly realistic combat scenarios. In this context, first-person shooter video games portraying armed conflicts are especially interesting to look at in terms of the images of international humanitarian law that they convey. I will start here by giving a brief overview of the core principles of international humanitarian law (A) and will then analyse their depiction in first-person shooter armed conflict video games (B).
A brief overview of international humanitarian law
The International Committee of the Red Cross (ICRC), the international organisation ensuring humanitarian protection and assistance for victims of war and other situations of violence, defines International humanitarian law (IHL) as “a set of rules which seek, for humanitarian reasons, to limit the effects of armed conflict”. It is a legal framework applicable to situations of armed conflict and occupation. IHL can trace its origins in the rules of ancient civilizations and religion. As part of public international law, it is made up of a set of treaties, customary law, principles and norms. A major part of it is contained in the four Geneva Conventions of 1949 and its two Additional Protocols of 1977 relating to the protection of victims of armed conflicts as well as its third Additional Protocol of 2005relating to additional distinctive emblems. It also includes other agreements which prohibit the use of certain weapons and military tactics, such as the 1972 Biological Weapons Convention or the 1997 Ottawa Convention on anti-personnel mines, and protect certain categories of people and goods, like the 1954 Convention for the Protection of Cultural Property in the Event of Armed Conflict and its two protocols, or the 2000 Optional Protocol to the Convention on the Rights of the Child on the involvement of children in armed conflict.
At the heart of IHL, there is the following two main principles: protection of those who are not, or no longer, taking part in fighting; restriction on the means of warfare (weapons and methods). These two principles give rise to several rules which must be respected during the conduct of hostilities. For example, they give rise to the obligation to treat humanely all persons who do not or are no longer taking active part in hostilities, including those who have laid down their arms and those placed hors de combat, and to protect these persons against all acts of violence (murder, mutilation, cruel treatment and torture, outrage upon personal dignity, etc). Protected people, places and objects can be identified through clearly recognizable symbols like the red cross or the red crescent. These principles also mandate an obligation to respect a duty to take precautions to spare the civilian population before and during an attack as well as to abide by the principles of distinction and proportionality, i.e for parties to the armed conflict to distinguish, at all times, between civilians and combatants and between civilian objects and military objects. Additionally, an attack may not be launched if it is anticipated to cause incidental loss of civilian life, injury to civilians, or damage to civilian objects that would be excessive in relation to the direct military advantage anticipated.
The international law of armed conflict in first-person shooter video games portraying realistic combat situations
IHL only applies to armed conflict and doesn’t cover internal tensions or disturbances such as isolated acts of violence. Therefore, we are going to focus only on first-person shooter video games portraying situations of armed conflicts, where players fire at enemy targets on contemporary battlefields.
The first enquiry into IHL in video games was made in 2009 by two Swiss organizations, Pro Juventute and TRIAL. They published a report entitled Playing by the Rules: Applying International Humanitarian Law to Video and Computer Games which aimed at “rais[ing] public awareness among developers and publishers of the games, as well as among authorities, educators and the media about virtually committed crimes in computer and videogames, and to engage in a dialogue with game producers and distributors on the idea of incorporating the essential rules of IHL and IHRL [International Human Rights Law] into their games which may, in turn, render them more varied, realistic and entertaining”. It didn’t gain much attention back then and the debate didn’t gain any traction until the ICRC decided to take up the subject two years later. The ICRC, notably, organized a side event to the 31st International Conference of the Red Cross and Red Crescent in November 2011 in which participants had the occasion to explore the role that the law of armed conflict plays, or does not play, in simulations of war. In 2012, Ben Clarke, Christian Rouffaer and François Sénéchaud, three academics affiliated with the ICRC, published a study on the subject entitled Beyond the Call of Duty: why shouldn’t video game players face the same dilemmas as real soldiers ?. Both reports conducted an analysis of several first-person shooter video games portraying combat situations like Call of Duty, Arma and Battlefield and tried to spot instances of violation of IHL rules in the games as well as the eventual consequences of these violations on the players. They both made similar findings: most of the games analysed contained massive violations of IHL norms, which were either awarded or ignored in the course of the game play. For example, in Call of Duty 5 (World at War), it was found that the game contains the possibility to shoot injured soldiers, which is clearly prohibited by IHL rules as we have seen in the previous section.
The general finding in both reports is that several messages conveyed by these video games reflect and reinforce certain ideas that pose a direct challenge to IHL:
- War is a law-free zone: In most of these video games, inflicting injury or death is normal and the only option available. The law applicable to the situation portrayed in the game is rarely, if ever, acknowledged or enforced. For example, in some video games, players must retrieve identity discs from the enemy combatants that they have killed in order to validate these kills and be rewarded. However, this is forbidden by IHL rules which require parties to an armed conflict to take measures to ensure that people do not go missing. These tags serve to identify the bodies of those who fall in combat so their fate can be recorded and their families informed. In a real combat situation, collecting these tags would be a violation of the 2006 International Convention for the Protection of All Persons from Enforced Disappearance.
- Anything living on a battlefield is to be shot at without distinction: One of the most frequent violations found in the TRIAL and Pro Juventute report were violations of the principle of distinction and proportionality. In many of these games, use of force resembles sport and players hunt virtual human beings by intentionally directing attacks against civilians.
- Civilian facilities can be attacked: An important portion of the violations found included extensive destruction of civilian property and attacks directed at religious buildings such as churches and mosques. Interestingly enough, in one of the games, attacking a church ended in mission over but the same did not happen when attacking mosques. It implies a certain conception of what is considered a legitimate target for attack or not and confirms Barthes’ argument in Criticism and Truth that literature is informed by power dynamics and carries ideology.
- The ends justify the means: In many video games, enemy fighters are depicted as treacherous villains and often labelled “terrorists” who deserve brutal treatment including summary execution or torture. Cruel, inhuman or degrading treatment and torture took second place in the list of common violations of IHL observed in the studied video games.
We can, therefore, see that the most common imagery of the law of war depicted in video games is its total absence, thus vehiculating the image that war is a law-free zone where everything is permitted for the sake of victory.
Interactions Between International Humanitarian Law and The Video Game Industry
In Law and Popular Culture, Richard Sherwin argued that “there is a two-way traffic between law and popular culture.” (Sherwin, 2004) This traffic is quite visible in our case study as, on one side, the enquiry into international humanitarian law rules in first-person shooter games has led to a call for the inclusion of these rules in video game scenarios (A) and , on the other side, it has led to the use of video games to teach international humanitarian law in some law schools (B).
The call for the integration of international humanitarian law principles in video game scenarios
Law as a discourse gives a repertoire for interpretation and that is what the ICRC has endeavored to do by finding legal meaning in video games portraying combat situations. They believe that “video games pose two important challenges to humanitarian norms. The first is their tendency to trivialize violations of the law. No less important is their potential undermining effect on perceptions of the normative framework among players (who include current and potential combatant, opinion-makers, lawmakers, decision-makers, and the general public)” and, therefore, argue that IHL rules should be integrated in game scenarios. The argument has two interesting components.
The first one is based on a call to pursue realism to its maximum potential. Indeed, the scope of the enquiry was specifically limited to video games that simulate real-war situations. As video games look more and more realistic, we buy even more into the images that they are conveying to us and the distinction between real and fiction ceases to matter.
Sherwin explained that “because photography, film and video images appear to resemble reality, they tend to arouse cognitive and especially emotional responses similar to those aroused by the real thing depicted” (Sherwin, 2004). The ICRC affiliated academics argued that in the same way that these video games offer players the possibility to use the latest weapons against enemy combatants on contemporary battlefields and apply the laws of physics to render a realistic feel, they should also reflect the dilemmas of modern combatants by incorporating IHL rules on the use of force in warfare.
The second component of the argument is that this integration of IHL rules is especially important because of the existing collaboration between the video game industry and the military. Video games are both used as training and recruitment tools and aim to give viewers a virtual experience of what being a soldier is like. For example, one of the US Army’s most powerful recruitment tool has been the multiplayer video game America’s army, a first-person shooter released in 2002, developed and published by the U.S. Army. It was explicitly designed as a recruitment tool and was used as a vector to communicate information of interest to potential recruits (equipment, salaries, career opportunities, etc.) and inculcate military values. Taking into account this proximity which further blurs the line between actual battlefields and virtual ones, it seems even more important for these video games to incorporate IHL norms as they are potentially played by future soldiers who will have to eventually face these situations in real life. Portraying war as lawless could potentially have an influence on what they consider permissible or not in the heat of the moment. Including IHL norms in these games, thus, offers the promise of a greater respect for them on tomorrow’s battlefield.
The video game industry has heeded the call and many of them have taken initiatives to incorporate IHL rules in their game scenarios since the publication of the mentioned reports. For example, Arma II now includes a surrender option for players or enemy troops and several other games have built rules and penalties into the script by penalizing characters for killing civilians or including warnings for players against acts that could be construed as violations of IHL if they occurred in a real armed conflict. For example, in Call of Duty – Modern Warfare 3, if the player chooses to shoot a civilian, the missions instantly end in failure.
The use of video games to teach international humanitarian law
In the same way that the law has influenced popular culture and has encouraged video games makers to include IHL rules in game scripts, this enquiry has also influenced some law professors who have decided to use video game simulations as a teaching tool for international humanitarian law. Indeed, The School of Law at Queen’s University Belfast has developed a series of innovative computer scenarios based on the Arma 3 open world tactical war simulator to assess students’ legal understanding of IHL rules in the face of increasingly challenging conflict situations. The teachers argued that “for students, learning about the law of armed conflict from books provides only one source of knowledge and understanding. Witnessing conflict and its consequences is key to appreciating the impact of decisions and obligations during combat.”. However, faced with the moral and ethical issues around using real war-related footage to provide them with the opportunity to witness conflict, video games came in as a very useful tool to achieve the professor’s aim to bridge the gap between black letter law and real-word application.
We can, therefore, conclude that most first-person shooter video games portraying situations of armed conflicts in a realistic manner tend to vehiculate an image of war as a lawless zone in which everything is permitted in the name of victory. This portrayal has been deemed, by the International Committee of the Red Cross, to be particularly dangerous and worrying because of the interconnections between the video game industry and military apparatus in countries like the United States of America, for example, in which video games are sometimes used as a recruitment tool for the army and where the video game industry regularly receives input from ex-military personnel who served on contemporary battlefields to craft their games and make them increasingly realistic. This subject demonstrates quite well the influence that popular culture can have on the law and vice versa, as the absence of IHL norms in virtual battlefields has been conceived by a part of the legal community as a danger to the very application and respect for IHL norms on real battlefields.
 Richard Sherwin, “Law in Popular Culture”, Articles & Chapters, 2004.
 James Boyde White, The Legal Imagination: Studies in the Nature of Legal Thought and Expression (Little, Brown, 1973)
 Marijane Camilleri, “Lessons in Law from Literature: A Look at the Movement and A Peer at Her Jury”, Catholic University Law Review, Volume 30, Issue 2, Winter 1990.
 Robert Weisberg, “The Law-Literature Enterprise”, Yale Journal of Law & the Humanities, Vol. 1:1, 1988.
 Richard K. Sherwin is an expert on the multiple connections that link law and culture, focusing in particular on legal storytelling and visual communication. He teaches at New York Law School. His biography is available here: https://www.nyls.edu/faculty/richard-k-sherwin/
 A first-person shooter is a popular type of video game that involves the gamer playing from the personal point of view of a soldier – seeing the weapon in their hands and shooting at targets as they appear on the screen.
 The Call of Duty franchise is a series of first-person shooter games developed by Activision Blizzard. The Battlefield series of games have been running since 2002 and are developed by EA DICE. Arma is a series of first-person tactical military shooters, developped by Czech studio Bohemia Interactive.
 Jennifer Hansler, “OSCE report finds “clear patterns” of violations of international humanitarian law by Russian forces in Ukraine”, CNN, April 13, 2022. Available at: https://edition.cnn.com/2022/04/13/politics/osce-moscow-mechanism-report-ukraine-russia/index.html
 Lorenzo Vallee, Pierre-Alex Beddiar, “Computer Space; et le jeu créa la forme”, Osibo News, November 19, 2012, available at: http://osibo-news.com/computer-space-et-le-jeu-crea-la-forme/
 Teodora Dobrilova, “How Much Is the Gaming Industry Worth in 2022 ? [+25 Powerful Stats], Techjury, March 12, 2022, available at: https://techjury.net/blog/gaming-industry-worth/#gref
 Detroit: Become Human is a franco-american game developped by Quantic Dream and edited by Sony Interactive Entertainment, it was released on May 25, 2014 for PlayStation 4. For more information, see: https://www.quanticdream.com/en/detroit-become-human
 Roland Barthes, The Death of the Author (1967)
 Elden Ring is an action-adventure role play game (RPG) developped by FromSoftware, Inc and Released in february 2022. It received a perfect score of 10/10 from most game reviewers such IGN, Gamespot or Gaming Bible. For more information, see: https://en.bandainamcoent.eu/elden-ring/elden-ring
 ICRC Advisory Service on International Humanitarian Law, “What is International Humanitarian Law”, available at: https://www.icrc.org/en/doc/assets/files/other/what_is_ihl.pdf
 International Justice Resource Center, International Humanitarian Law, available at: https://ijrcenter.org/international-humanitarian-law/
 Cf. 19.
 Convention (I) for the Amelioration of the Condition of the Wounded and Sick in Armed Forces in the Field. Geneva, 12 August 1949, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/365?OpenDocument ; Convention (II) for the Amelioration of the Conditions of Wounded, Sick and Shipwrecked Members of Armed Forces at Sea. Genea, 12 August 1949, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/370?OpenDocument ; Convention (III) relative to the Treatment of Prisoners of War. Geneva, 12 August 1949, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/375?OpenDocument ; Convention (IV) relative to the Protection of Civilian Persons in Time of War. Geneva, 12 August 1949, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/380?OpenDocument
 Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I), 8 June 1977, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/470?OpenDocument ; Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of Non-International Armed Conflicts (Protocol II), 8 June 1977, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/475?OpenDocument
 Protocol additional to the Geneva Conventions of 12 August 1949, and relating to the Adoption of an Additional Distinctive Emblem (Protocol III), 8 December 2005, available at: https://ihl-databases.icrc.org/applic/ihl/ihl.nsf/INTRO/615?OpenDocument
 1972 Convention on the Prohibition of Biological Weapons, available at: https://www.icrc.org/en/document/1972-convention-prohibition-bacteriological-weapons-and-their-destruction-factsheet
 1997 Convention on the Prohibition of the Use, Stockpiling, Production and Transfer of Anti-Personnel Mines and on their Destruction, available at: https://www.un.org/disarmament/anti-personnel-landmines-convention/
 The 1954 Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict and its two (1954 and 1999) Protocols, available at: https://unesdoc.unesco.org/ark:/48223/pf0000187580
 Optional Protocol to the Convention on the Rights of the Child on the involvement of children in armed conflict, 25 May, 2000, available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/optional-protocol-convention-rights-child-involvement-children
 Article 3 (1) common to the 1949 Geneva Conventions
 Article 3 (1)(a) and (c) common to the 1949 Geneva Conventions
 Article 57 Additional Protocol I, Art 51 Additional Protocol I and Article 3 annexed to the 1980 Convention on Prohibition or Restrictions on the Use of Certain Conventional Weapons
 Cf. 20
 Cf. 19
 Pro Juventute is a foundation created in 1912 by the Swiss company for public utility to accompan fight against tuberlosis in childrend and young people. They accompany parents and provide support to children and young people to allow them to become responsible and autonomous persons. Website available here: https://www.projuventute.ch/fr
 TRIAL International is a swiss NGO which has for aim to fight against impunity of international crimes and provide support to victims in their quest for justice. Website available here: https://trialinternational.org/fr/
 Pro Juventute, TRIAL, “Playing by the Rules: Applying International Humanitarian Law to Video and Computer Games”, October 2009, available at: https://trialinternational.org/wp-content/uploads/2016/05/Playing_by_the_Rule.pdf
 ibid. p 3.
 Ben Clarke, Christian Rouffaer and François Sénéchaud, “Beyond the Call of Duty: why shouldn’t video game players face the same dilemmas as real soldiers?” International Review of the Red Cross, Volume 94 Number 886 Summer 2012
 Cf. 36, p 26.
 Cf. 36
 Cf. 39
 International Convention for the Protection of All Persons from Enforced Disappearance, New York, 20 December 2006, available at: https://treaties.un.org/pages/ViewDetails.aspx?src=TREATY&mtdsg_no=IV-16&chapter=4
 Cf. 39
 Cf. 36
 Roland Barthes, Criticism and Truth (1966)
 Cf. 39
 Cf. 36
 Cf. 39
 Cf. 39
 Joseph Knoop, “America’s Army is Shutting Down After 20 Years”, IGN, February 9, 2022, available at: https://www.ign.com/articles/americas-army-shut-down
 Cf. 39
 Luke Moffet, Dug Cubie & Andrew Godden, “Bringing the battlefield into the classroom: usign video games to teach and assess international humanitarian law”, The Law Teacher, 51:4, 2017, pp 499-514, available at: https://doi.org/10.1080/03069400.2017.1356659
 There has been for example commercial-military collaboration to develop games like Call of Duty Black Ops 2. see “Documentary – Official Call of Duty Black Ops 2”, available at: https://www.youtube.com/watch?v=Gm5PZGb3OyQ&ab_channel=CallofDuty