This article's writer actually developed a reasoned explanation for why he feels that games are not yet art.
http://www.nytimes.com/2007/09/28/opinion/28radosh.html?_r=2&ref=opinion&oref=slogin&oref=slogin
I think he's referencing Planescape: Torment towards the end there. That was a rare game where the game's content specialized on non-combat events and role-playing, and combat was minimized or potentially bypassed altogether in some areas.
http://www.nytimes.com/2007/09/28/opinion/28radosh.html?_r=2&ref=opinion&oref=slogin&oref=slogin
I think he's referencing Planescape: Torment towards the end there. That was a rare game where the game's content specialized on non-combat events and role-playing, and combat was minimized or potentially bypassed altogether in some areas.