Many video games, as early as 1976's "Death Race", incorporate some aspect of violence into the gameplay mechanic, such as killing an enemy with a weapon, using explosives to destroy a structure, or engaging in dangerous vehicle races. With modern technology, representations of such violence have become more realistic. This has led to concerns that minors who play such video games will be influenced by the violence, altering their real-life behavior. Academic studies have attempted to find a connection between violent video games and the rate of violence and crimes from those that play them; some have stated a connection exists, while others find no link between the matters. Incidents such as the Columbine High School massacre in 1999 have heightened concerns of a potential connection between video games and violent actions. Accordingly, many concerned groups including politicians and parents have sought to enact regulatory controls of video games to prevent their sales to youth. Prior and during the "Brown v. EMA" case, parties like the Entertainment Software Association (ESA) sought to overturn similar state laws that placed limits on the sales of violent video games to minors in Michigan and Illinois. The ESA won these cases, with the laws being found unconstitutional and overly restrictive of protected speech. These states did not further challenge the court rulings. The ESA similarly defeated a Louisiana bill in the 2006 "Entertainment Software Association v. Foti" case that would have attempted to ban sales of violent video games to minors.