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> This is done for commercial, not legal reasons; if the companies didn't want to advertise their games, they wouldn't have to abide by USK guidelines.

That's a ban by any reasonable standard. That's like saying that a requirement that churches be built on the moon wasn't banning churches, or a requirement that Jews who own businesses pay a 95% tax isn't a ban on Jews owning businesses. In some technical sense it's not a complete ban, but if the government says that if you do X, you face so many restrictions that you'd go broke, that's defacto a ban. It's an excuse made by people who like to pretend that they're not getting their hands dirty by literally banning something, while banning it in practice.



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