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Empire City: 1931 is set during the American prohibition era, in an unnamed, crime-ridden city. The player is a vigilante determined to stop the mafia's control over the city.
The player controls a crosshairs with a joystick, and has a "shoot" and "defend" button. As enemies appear off-screen, a countdown appears, indicating the length of time the player has to fire at, or defend against an enemy. Shooting an enemy nets points, while defending allows the player to evade gunfire, at the expense of ammunition.
Points are scored by shooting enemies, saving (not shooting) civilians, and by shooting occasional bonus items (such as a very small flying Superman which appears in certain stages). Ammo is periodically replenished by shooting at ammo boxes. A Thompson sub-machine gun is occasionally available for a limited period of time.