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>everyone wins or every one loses an equivalent amount

That's not a factor WRT the law in question.

The law states that if you take money or some financial consideration for a chance (that is not based on your skill) of receiving something of value, then it is effectively an illegal lottery. It doesn't matter whether everyone wins or loses.

This is usually addressed by allowing people to enter without making a purchase (entry form, postcard, etc). But, here, that obviously would be an insane offer, so doesn't really apply.




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