  Suits also offers a shorthand definition: ‘playing a game is the voluntary attempt to overcome unnecessary obstacles’ (Suits, 1978 [2014, 43]). Suits’ account of games has attracted much critical attention. Principal among the objections raised are that games are not constituted by their constitutive rules only (D’Agostino, 1981; Russell, 1999) and that gameplaying does not require strict adherence to constitutive rules (i.e. some rule-breaking can be consistent with game-playing) (Lehman, 1981; Fraleigh, 2003).