While there is no doubt that their will be an increasing trend towards 3D games on mobile devices the resource constraints of the devices themselves and the highly variable nature of the environment present considerable challenges for games developers. In this paper we consider some of the current constraints together with current and, probable, future developments both in the software and hardware of mobile phones that will enable more sophisticated games to be developed. As part of this process we benchmark some of the latest and most prevalent software and devices to ascertain both the quality of the graphics produced and the effects on the battery life. Whilst we are certain that 3D games will play an important future in the success of future mobile services the current baseline for development is highly variable and presents difficulties for games programmers both in development and wide scale distribution.