It’s the holiday season, which means the annual report card on violent video games from National Institute on Media and the Family. Not surprisingly, Doom 3, Half-Life 2, and Grand Theft Auto: San Andreas were among those on the list of games that are naughty, not nice.

Cities and states have long attempted to ban such games from minors, but with little success. Governor Gary Locke of Washington enacted a law banning the sale of violent games to kids under 17; but the law was put on hold after video game industry attorneys questioned the ruling as a violation of free speech. Games as free speech is hardly a slam dunk, however. In 2002, after St. Louis failed to pass a similar ordinance, U.S. District Judge Stephen N. Limbaugh Sr. said that video games have “no conveyance of ideas, expression, or anything else that could possibly amount to speech.”

For now, the report from the National Institute on Media and the Family will surely stoke the fire of controversy – and, ultimately, sell a few more games.