London, January 26, 2026 — The UK Competition Appeal Tribunal has certified an opt-out collective proceedings order (CPO) allowing a consumer claim against Valve Corporation to proceed, finding that the proposed class action meets the statutory requirements under the Competition Act 1998.
In a unanimous judgment, the Tribunal authorised Vicki Shotbolt Class Representative Limited to act as the proposed class representative in proceedings alleging that Valve abused a dominant position through its Steam digital distribution platform. The claim is brought on behalf of UK-based consumers who purchased PC games and related add-on content during the relevant period.
Scope of the Proposed Class
The proceedings are brought on an opt-out basis, meaning eligible consumers will automatically be included unless they choose to opt out. The Tribunal accepted evidence that the proposed class could include up to approximately 14 million consumers across the UK.
The claims relate to purchases of PC games and add-on content, including downloadable content, subscriptions, and in-game purchases, whether bought directly through Steam or through other channels such as download codes redeemable on the platform. Aggregate damages are provisionally estimated at up to £656 million, with individual losses estimated to average between £22 and £44 per class member.
Alleged Abuses of Dominance
According to the proposed class representative, Valve is dominant in several related markets, including the sale and distribution of PC games and add-on content. The claim alleges that Valve abused that position in three main ways.
First, Valve is accused of imposing platform parity obligations that prevented publishers from offering games or add-on content on better terms through competing channels than on Steam. The Tribunal described these obligations as wide in scope and affecting both direct sales by publishers and sales through alternative distribution platforms.
Second, the claim alleges that Valve imposed restrictions requiring in-game purchases for Steam-enabled games to be processed through Valve’s own payment systems, thereby subjecting those transactions to Valve’s commission charges.
Third, the claim alleges that Valve’s commission rates — historically set at 30% and later subject to a tiered structure — were excessive and unfair, with the resulting costs passed on to consumers through higher prices.
Certification Challenges Rejected
Valve opposed certification, arguing that the proposed methodologies for assessing liability and harm were inadequate. In particular, Valve challenged the ability of the proposed class representative to account for Steam Keys — download codes issued by Valve that can be sold through third-party channels and redeemed on Steam without a commission being charged.
Valve argued that uncertainty surrounding the pricing and volume of Steam Key sales made it impossible to determine Valve’s effective commission rate or assess whether that rate was unfair. The CAT rejected this argument, concluding that while Steam Keys introduced evidential complexity, they did not render the claim unsuitable for collective proceedings.
The Tribunal found that the proposed methodologies satisfied the applicable test at the certification stage, emphasising that precision was not required at this early phase and that reasonable assumptions could be applied at trial if necessary.
Valve also challenged the proposed methodology for assessing the competitive effects of the alleged platform parity obligations. The Tribunal held that the proposed approach, which combined economic theory with documentary evidence, market data, and potential disclosure from Valve, was sufficient to allow the claims to be fairly and effectively tried.
Authorisation and funding
The Tribunal also concluded that it was just and reasonable for Vicki Shotbolt Class Representative Limited to act as the class representative. It found no material conflicts of interest and was satisfied that the representative had adequate governance, funding, and insurance arrangements in place.
While noting that funding arrangements in collective actions require careful scrutiny, the Tribunal found no evidence that the terms in this case were inappropriate or outside market norms.
Opt-out proceedings confirmed
In deciding to certify the case on an opt-out basis, the CAT held that opt-in proceedings would not be practicable given the size of the class and the relatively small individual losses involved. The Tribunal described the case as a paradigm example of when opt-out collective proceedings are appropriate.
The case is 1640/7/7/24 Class Representative Vicki Shotbolt Class Representative Limited v Valve Corporation before the Competition Appeal Tribunal.
Source: https://www.catribunal.org.uk/cases/16407724-vicki-shotbolt-class-representative
