Thompson had previously been involved in a number of suits against Rockstar regarding in-game violence from previous Grand Theft Auto titles as a possible influence on murderers who played the games. In the middle of July 2005, politicians including U.S Senator Hillary Clinton (D-NY) launched an FTC investigation into the Hot Coffee mod following the re-rating of Grand Theft Auto: San Andreas by the ESRB (see re-ratings). Clinton had urged her colleagues to 'take immediate action to determine the source of graphic pornographic and violent content appearing on the Grand Theft Auto: San Andreas video game.' This led to a U.S. House Resolution introduced by Congressman Fred Upton (R-MI) to determine if Rockstar had intentionally deceived the ESRB to avoid an Adults Only rating.