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RolStoppable said:

You are correct about MGS4, but Heavy Rain and The Order 1886 were funded by Sony, plus they hold the IP rights.

 

Second-party developer is a colloquial term used by gaming enthusiasts and media often used to describe two different types of game development studios:

  1. Independently owned studios who take development contracts from the platform holders and what they produce will usually be exclusive to that platform.
  2. Studios who are partially or wholly owned by the platform holder (also known as a subsidiary) and what they produce will usually be exclusive to that platform.

In reality, the resulting game is first party (since it is funded by the platform holder who usually owns the resulting IP), but the term helps to distinguish independent studios from those directly owned by the platform holder. These studios may have exclusive publishing agreements (or other business relationships) with the platform holder, while maintaining independence. Examples are Insomniac Games (which previously developed games solely for Sony's PlayStation platforms as an independent studio) and Game Freak (which primarily develops the Nintendo-exclusive Pokémon game series).

 

Sony can't be blamed for the quality of a game they chose to fund, not to develop. Hence why they should be treated like second-party, not first, which the author of the news use in order to have more games to compare the "failures".