South Korea Fines Samsung 20.114 Billion Won Over Undisclosed Galaxy Gaming Limits

Gaming promises meet a 20.114 billion won penalty

South Korea's Fair Trade Commission has decided to impose a 20.114 billion won fine on Samsung Electronics and ordered corrective measures over advertisements for Galaxy S21 and S22 smartphones and Galaxy Tab S8 tablets. The regulator said Samsung promoted their gaming performance without telling buyers that certain demanding games immediately triggered preset performance limits.

The advertising examined ran from January 15, 2021, to March 21, 2022. In one example involving a Galaxy S22 running PUBG: New State, the maximum processor clock speed was capped at 0.94GHz rather than 2.99GHz, while the graphics processor was limited to 220MHz rather than 818MHz.

Those settings left the processor at 31.4% of its maximum clock speed and the graphics chip at 26.9%. The commission said the restrictions applied as soon as selected games launched, regardless of the device's temperature or condition.

Samsung disputes the decision and plans to challenge it through administrative litigation. The company says its Game Optimizing Service, known as GOS, was designed to manage heat and support stable gaming over longer sessions. The dispute turns on what buyers were told about the relationship between the hardware Samsung advertised and the limits its software applied.

What Samsung advertised to buyers

Samsung highlighted gaming across its website, promotional videos, product launches and press releases. Its advertising promoted fast processors, responsive touch controls and smooth screen transitions, placing gaming at the centre of the appeal of these premium devices.

The campaigns included a claim about the fastest 5nm application processor in Galaxy history and promoted a display with a refresh rate of 120Hz. An application processor is the main chip that handles a phone's computing work. A 120Hz display can refresh its image 120 times per second, helping movement look smoother when the rest of the device and the game can keep up.

The commission said gaming performance was an important consideration for consumers buying expensive smartphones and tablets. Fast movement and detailed graphics offered a visible way to demonstrate the devices' capabilities, making undisclosed restrictions relevant to a purchasing decision.

The finding concerned an omission: Samsung advertised a particular strength while leaving out information about a software policy that limited that strength during some of the activities being promoted.

How the gaming limits worked

GOS manages performance when games are running, including measures intended to control heat and power consumption. The policy examined by the commission placed predetermined ceilings on processor and graphics chip speeds, as well as screen refresh rates, when particular demanding games started.

A CPU, or central processing unit, handles instructions and calculations. A GPU, or graphics processing unit, draws the images shown on screen. Their clock speeds describe how quickly they perform operating cycles. Restricting those speeds reduces the computing capacity available to a game at that moment.

The commission's concern was that the restrictions started immediately, even when the device's temperature or operating condition would otherwise allow more performance. Consumers could buy a device for its advertised hardware capabilities and then encounter a lower ceiling when opening a game covered by the policy.

The CPU and GPU speed restrictions covered 82 games on the Galaxy S21 series, 47 on the S22 series and eight on the Tab S8 series. Those counts describe games subject to the policy on each product family; the same title could appear on more than one device's list.

What players experienced

Galaxy users complained of freezes, stuttering, slower responses and reduced graphics quality. The commission said the restrictions could affect moments when games needed more processing power, such as scenes involving rapid movement or demanding visual effects.

A Galaxy S22 buyer identified by the surname Im described the phone becoming hotter, GOS activating and graphics automatically falling to a lower quality. The buyer said the resulting experience differed from what had been expected after seeing the advertising.

The PUBG: New State example shows the size of the hardware limits in concrete terms. The CPU ceiling fell by 2.05GHz, from 2.99GHz to 0.94GHz. The GPU ceiling fell by 598MHz, from 818MHz to 220MHz. Put simply, the permitted clock speeds were around one third and just over one quarter of their respective maximums.

Samsung's lawyers dispute how the commission connected those settings to actual gameplay. Their objection focuses on another measure that matters to players: frames per second, or how many images a game produces each second. Clock speed measures chip operation, while frames per second measures part of the visible result on screen.

Why the commission found the advertising deceptive

The commission cited Article 3(1)(2) of South Korea's Act on Fair Labeling and Advertising, which addresses deceptive advertising. It concluded that leaving out the immediate, uniform performance limits could lead consumers to overestimate the devices' gaming capabilities and interfere with informed purchasing decisions.

The commission explained its finding in terms of the information missing from Samsung's campaigns:

Samsung Electronics failed to disclose in its advertisements that the devices' maximum performance was uniformly restricted immediately upon launching high-spec game apps, thereby deceiving consumers and hindering their rational purchasing decisions.

Lee Young-hee, a director in the commission's Labeling and Advertising Monitoring Division, said companies promoting a particular product capability should clearly disclose important restrictions affecting it. For a buyer comparing premium devices, that means knowing both the advertised capability and the conditions under which software limits access to it.

The corrective order accompanies the financial penalty. Details of the required corrective measures and a date for Samsung's planned legal challenge were not specified.

Samsung challenges the regulator's reasoning

Samsung says GOS was intended to improve the gaming experience over time by managing heat and supporting stable operation. Its position centres on sustained play rather than keeping a device at its maximum processor speed throughout a session.

The company also says global smartphone manufacturers commonly use comparable optimisation functions. Samsung maintains that no overseas competition authority has sanctioned such a function or judged it to constitute misleading advertising.

Samsung's legal representative, Jipyong LLC, disputes the commission's technical analysis. The firm says the regulator focused on the ratio between preset clock speed limits and the application processor's maximum speed without setting out the specific effect on actual gameplay, including frames per second.

Samsung also objects to the timing of the decision, pointing to the conclusion of related lawsuits and the withdrawal of the complaint to the commission. In its response, the company said:

This decision is difficult to understand given that all domestic and international lawsuits have concluded and the complainants involved in the lawsuits have withdrawn their reports to the KFTC. We will actively present our position through legal procedures moving forward.

The March 2022 update changed user control

Samsung changed the software in March 2022, lifting the CPU and GPU speed restrictions at issue. It also made a Game Performance mode available, allowing users to select less restrictive temperature control, and removed measures that had blocked ways of bypassing the GOS policy.

Before that change, users could not delete the function. The update gave owners more control over the balance between performance and temperature management, addressing a practical part of the controversy.

The advertising investigation still concerned what consumers knew when choosing their devices during the period under review. Buyers had already made purchases based on campaigns that presented gaming performance as a major advantage.

The sequence stretches from the launch of the Galaxy S21 to software changes and later regulatory action:

• January 15, 2021: The advertising period examined by the commission began.
• Early 2021: Samsung released the Galaxy S21 series.
• 2022: The Galaxy S22 and Galaxy Tab S8 arrived, and complaints about gaming performance intensified.
• March 2022: Samsung changed the software to lift the CPU and GPU speed restrictions and allow greater user control.
• March 21, 2022: The advertising period covered by the finding ended.
• October 27: The commission announced its decision to impose a fine and corrective measures, prompting Samsung's planned challenge.

Earlier lawsuits ended before this dispute

Eight related lawsuits in South Korea, the United States and Israel had concluded before Samsung announced its response to the commission's decision. The company cited those outcomes, along with the withdrawn regulatory complaint, as reasons for its opposition.

In the South Korean litigation, the court at first instance accepted that the advertising was deceptive but denied liability for damages. The Seoul High Court subsequently issued a compulsory mediation decision in February, which became final in March after roughly 1,700 plaintiffs and mediation participants did not object.

The earlier court proceedings concerned consumer claims for compensation. The commission's action concerns compliance with advertising law and a financial penalty imposed by the regulator. Samsung's planned administrative case would challenge that regulatory decision.

What the dispute means for Galaxy buyers

Owners of the affected devices have already received the software changes described in the case. The new regulatory action focuses on Samsung's earlier advertising, while the company's planned challenge brings the legal reasoning and technical assessment into dispute again.

For consumers comparing phones and tablets, the case shows why a chip specification and the experience of playing a demanding game can differ. Hardware sets a device's potential capacity; software determines how much of that capacity a particular application can use under particular conditions.

The central disagreement is concrete. The commission says Samsung should have disclosed preset restrictions when promoting gaming performance. Samsung says its software served a legitimate optimisation purpose and challenges the analysis connecting those restrictions to the experience players received.

Key Points

• The commission decided to fine Samsung 20.114 billion won and ordered corrective measures over Galaxy gaming advertisements.
• The finding covers Galaxy S21 and S22 smartphones and Galaxy Tab S8 tablets advertised from January 15, 2021, to March 21, 2022.
• Selected games triggered preset limits regardless of device temperature or condition.
• In one Galaxy S22 example, CPU and GPU clock ceilings were 31.4% and 26.9% of their maximums.
• Samsung changed the software in March 2022 and gave users greater control over performance settings.
• Samsung disputes the decision and plans administrative litigation.