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WASHINGTON, Sept. 28--Acknowledging that some R-rated films have been intentionally marketed to children as young as 9, the nation's movie moguls went before the Senate Commerce Committee on Wednesday to offer a 12-point package of voluntary reforms they hope will avert congressional action to control such practices.

The entertainment industry executives argued that violent material was not the only, or even the leading, cause of youth violence in America and objected to government intervention in the movie-making business as unconstitutional.

The studio heads' performance and proposals received mixed reviews, with committee Chairman Sen. John McCain (R-Ariz.) angrily faulting them for being vague and creating loopholes.

"Why not simply say you will not market R-rated movies?" McCain asked. Other senators threatened legislative action if the industry doesn't take more effective steps soon.

The Hollywood executives said some marketing companies and movie studio officials were guilty of targeting children and that reforms were needed, but they denied that these marketing methods were an industry-wide policy.

"We have not always been as careful as we could have been," said Rob Friedman, vice chairman of Paramount Pictures. "I do not believe, however, that we systematically focus our advertising efforts for R-rated films toward young children."

In response to committee members' complaints that the violent, R-rated Bruce Willis film "The Fifth Element" was advertised to children younger than 12, Mel Harris, president of Sony Pictures Entertainment, called it "a lapse in judgment" by one executive.

The Hollywood representatives argued that voluntary self-policing was the answer. But they insisted that a total ban on such advertising would deprive studios of the right to market to teenagers some movies that would have redeeming educational or social value, despite possible R-ratings.

"We embrace these industry-wide initiatives and we'll work closely with our colleagues in the industry in their implementation," said Walter Parkes, a top executive with Steven Spielberg's DreamWorks SKG. "I do, however, want to stress that it is the...individual companies themselves that should take the leadership role in the implementation of these reforms."

The reforms, drawn up by the Motion Picture Association of America and announced Tuesday, generally call for self-imposed restrictions on the advertising and promotion of violent R-rated moviesspecially during television programs with more than 35 percent of viewers under age 18.

Other proposals include a stronger effort to control access to violent movies in theaters and increased policing by the industry of its member companies.

Several of the studio chiefs said they would halt all television advertising for R-rated films before 9 p.m. Robert Iger, president of Disney and Miramax films, agreed with a call by the Directors Guild of America for a universal system of content ratings that would apply to all films, video games and recordings equally.

Parental responsibility, however, was emphasized as the ultimate solution to the problem of exposing young people to violent films.

"Parents believe they should be the ones on the front line in deciding what films their children should see," Sony's Harris said. "They realize that every child is different and that a parent is best positioned to know whether his or her child is mature or sophisticated enough to handle a particular message. We believe the current movie rating system, augmented by the additional information that we and others provide to the public, gives parents the information they need and want to make an informed decision."

The rare appearance by studio executives was in response to national criticism sparked by a Federal Trade Commission report this month that accused the motion picture, recording and video game industries of "aggressively and pervasively" targeting advertising and marketing products with high violence contents at young teens and children in violation of their own rating codes.

Commissioned by President Clinton after last year's massacre at Columbine High School in Colorado, the study found that 80 percent of films rated R for violence were deliberately advertised and marketed to children younger than 17. Under the Motion Picture Association's rating system, children are supposed to be barred from such movies unless accompanied by an adult.

The study found that children as young as 9 were included in marketing study focus groups for R-rated and PG-13 films.

Studio officials who violated the new reform guidelines would be subject to firing, the industry leaders said.

The studio executives repeatedly stressed that any crackdown on marketing practices should not include an attempt to regulate movie content. They cited such highly praised films as "Saving Private Ryan," "Schindler's List," "Boyz in the Hood" and "Amistad" as deserving of teenage audiences despite their intensely graphic depictions of violence.

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