Are the sweepstakes legal?

I'm a lawyer. I emailed Eric on Monday expressing concern about the sweepstakes. I encouraged Eric, if he had not done so already, to run the sweepstakes by a lawyer.

I'm no expert in lottery laws; I'm not barred in California; I'm not giving legal advice. But when I read the Sweepstakes page, the "lawyer bells" went off in my head.

Specifically, I am concerned that people can enter multiple times with PucaPoints (paying consideration) but only one time via the free method (Twitter).

I spent 30 minutes on Google. So I didn't delve into the statutes. Just browsed a law review article that had this to say about the "equal dignity" rule: "A second concept of Equal Dignity is that non-paying participants should not face greater odds or obstacles to winning the prizes than paying participants face. For example, a person who enters by paying cannot get a disproportionate number of entries compared to non-paying entries."

There's a decent chance California follows this rule, but I'm not inclined to spend a day researching the issue: "[S]olicitation materials . . . cannot represent that an entry not accompanied by an order will have a reduced chance of winning." (also discussing criminal and civil penalties)

From PucaTrade's description of the sweepstakes, it appears to say that free entrants (Twitter) have a reduced chance of winning compared to paying entrants (PucaPoints) because paying entrants can enter multiple times, but Twitter entrants can only enter one time.

/r/PucaTrade Thread