In November 1991 there was an incident where a middle-schooler shoplifted an adult bishōjo game Saori: the House of Beautiful Girls, resulting in increased police scrutiny for makers and retailers.
Several prefectures began classifying games as obscene and pulling them off the shelves.
Particularly notable in this respect are Leaf's To Heart (1997), and Key's Kanon (1999).
Even though their gameplay involved little more than scrolling through text, they became hits largely due to the quality of their writing and characterization.
A notable landmark was Jast's Tenshitachi no gogo (1985), a precursor to the modern dating simulation.
Released in 1994 by Konami who was on the verge of bankruptcy, the platonic dating sim becoming the first major Bishojo game since Koei's release of Night Life. While the title was another eroge title targeted at males for its sexual content, the players began to identify with the protagonist and the idea overcoming "the emotional trials and tribulations of pure love." A late Play Station 2 port removed the sexual content and sold better than the original leading eventually to two anime adaptations. Dōkyūsei, whose gameplay focused on meeting girls and seducing them, established the standard conventions of the dating simulation genre.
Tokimeki Memorial, the first dating sim, featured good graphics, full voice acting, and a role-playing game-like gameplay system.
These came to national attention in Japan in 1986 with the release by d B-soft of 177, a game where the player takes the role of a rapist.
(The game's title originates from the number of the Japanese law criminalizing rape.) 177 was not actually the first game designed around this premise, but it was unusually explicit.