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3d illustration of laptop over white background with blue reflection screen and slot machine<\/p>\n
getty<\/p>\n
California has easily been the most aggressive state in tackling the ongoing problem of Internet sweepstakes caf\u00e9s. In 2015, the California Legislature enacted<\/a> Business and Professions Code section 17539.1(a)(12), which effectively outlawed land-based sweepstakes operations that \u201csimulate gambling\u201d or involve \u201cgambling-themed games.\u201d To this day, the California Bureau of Gambling Control continues to post a Law Enforcement Advisory warning<\/a> about internet sweepstakes cafe\u0301s, calling them \u201cillegal gambling operations.\u201d<\/p>\n Despite this clear prohibition, the internet caf\u00e9 business model has effectively transitioned<\/a> to the world wide web, according to several lawsuits<\/a> filed against Virtual Gaming World (VGW), the Australian-based operator of the leading sweepstakes-based casino websites Chumba Casino and Luckyland Slots. (VGW has been named in 17 lawsuits nationally, including several in California which seek to force VGW to \u201cshut down their illegal gambling websites\u201d for violating California\u2019s strict anti-gambling laws). \u201cThe gambling internet caf\u00e9 operations have transitioned into calling the internet home,\u201d one lawsuit proclaims<\/a>, pointing to VGW\u2019s alleged role in \u201cpioneering this migration of \u2018sweepstakes casinos\u2019 to the world wide web.\u201d<\/p>\n Because section 17539.1(a)(12)\u2019s ban against \u201cgambling-themed\u201d sweepstakes applies only to \u201cbusiness establishments,\u201d California lawmakers recently introduced Assembly Bill 831<\/a> to extend the prohibition to \u201conline\u201d gambling-themed sweepstakes games. AB 831 is consistent with the policy underlying \u00a7 17539.1(a)(12), which as the California Attorney General noted<\/a>, \u201cwas intended to assure that gambling-themed sweepstakes operations would be prohibited under the Unfair Competition Act (Bus. & Prof. Code \u00a7 17200) as unfair business practices.\u201d<\/p>\n VGW, both directly and via the Social Gaming Leadership Alliance, opposes<\/a> AB 831 on the basis that it \u201cseeks to criminalise online social games that leverage sweepstakes promotions.\u201d VGW and groups representing other sweepstakes casino operators have long maintained<\/a> that their online \u2018casino-style\u2019 sweepstakes games are legal because they offer free ways to enter.<\/p>\n But that is the same flawed argument that was historically advanced<\/a> by internet sweepstakes cafes \u2013 and courts throughout the U.S. (including in California<\/a>) have consistently rejected<\/a> it.<\/p>\n While VGW attempts to distance itself from the now-outlawed internet sweepstakes cafes \u2013 since its games are entirely online and involve a different product (i.e., virtual currency) \u2013 it willingly embraced the internet caf\u00e9 business model when seeking investors.<\/p>\n VGW prospectus touts \u201cinternet sweepstakes cafes\u201d as a business model<\/p>\n Back in January 2016, when it sought to raise capital in the equity markets, VGW admitted that its business model was comparable to the \u201cinternet sweepstakes cafes\u201d that have \u201cproliferated across the US over the last 10 years.\u201d Ironically, just one year earlier, California passed legislation banning<\/a> internet sweepstake cafes \u2013 a development apparently lost on VGW. In a prospectus<\/a> filed with the Australian Securities Exchange, VGW included an \u201cindependent industry report\u201d from H2 Gambling Capital \u2013 which is described as \u201cthe leading authority regarding market intelligence on the global gaming industry.\u201d The report (which follows page 66) \u201cprovided an assessment of the current US gaming market\u201d for investors.<\/p>\n The VGW-funded report highlighted<\/a> the proliferation and market size of internet sweepstakes cafes \u2013 \u201cover 5,000 now operating in 12 states\u201d with turnover exceeding $10 billion annually (see Prospectus, pp. 69 & 95) \u2013 as indicative of the \u201csignificant opportunity\u201d and \u201cconsiderable commercial need\u201d for \u201cInternet Sweepstakes Gaming\u201d in the U.S. market. (Id., pp. 96-97; \u00b6\u00b6 71 & 80 of H2 Report). The report<\/a> goes on to characterize the \u201cinternet sweepstakes caf\u00e9 business model\u201d as a \u201cland-based example that has evolved and proliferated across the US over the last 10 years\u201d (Id., p. 95) and stated that it \u201cmay be equally applicable as a business model\u201d for \u201cInternet Sweepstakes Gaming\u201d (Id., p. 97; \u00b6\u00b6 70 & 83 of H2 Report).<\/p>\n H2 Gambling Capital, Independent Industry Report prepared for Virtual Gaming Worlds in connection with Australian Securities Exchange (ASX) Listing, Jan. 2016, Section 3: US Internet Gaming, \u00b6\u00b6 67-68, publicly available at https:\/\/announcements.asx.com.au\/asxpdf\/20160104\/pdf\/4345wkvqbww4kk.pdf (captured Aug. 24, 2025).<\/p>\n Source: H2 Gambling Capital, 2015<\/p>\n The report<\/a> states that the size of the U.S. market for \u201cInternet Sweepstakes Gaming\u201d could be estimated based on \u201cthe total size of the US online real money gaming market (particularly casino, poker and lottery) if it was fully regulated and licensed across the US,\u201d adding that this \u201crepresents the market within which the internet sweepstakes cafe model presently operates\u201d: <\/p>\n H2 Gambling Capital, Independent Industry Report prepared for Virtual Gaming Worlds in connection with Australian Securities Exchange (ASX) Listing, Jan. 2016, Section 3: US Internet Gaming, \u00b6 71, publicly available at https:\/\/announcements.asx.com.au\/asxpdf\/20160104\/pdf\/4345wkvqbww4kk.pdf (captured Aug. 24, 2025).<\/p>\n Source: H2 Gambling Capital, 2015<\/p>\n Likewise, in an October 2015 press release<\/a> in Australia, VGW stated on the first page (bullet #3) that its social sweepstakes casino website \u2013 Chumba Casino \u2013 is \u201ctargeting the global casino market, particularly the unrealised United States real-money gaming market.\u201d<\/p>\n Indeed, the prospectus<\/a> refers to \u201cgambling\u201d 79 times, and noted that \u201cdespite significant prohibition, the US remains by far the largest gaming market in the world.\u201d (pp. 69 & 73).<\/p>\n The prospectus<\/a> confirms that the \u201ccore part\u201d of VGW\u2019s \u201cbusiness model\u201d is to combine \u201csocial casino gaming and cash prize gaming using Sweepstakes Credits\u201d \u2013 which it refers to as \u201cSocial Sweepstakes.\u201d (Prospectus, pp. 13, 18 & 62). Under its Social Sweepstakes model, \u201cSweepstakes Credits are generally awarded on a 1-for-1 basis, with a denomination of US$0.01 for each Sweepstakes Credit. For example, a US$10 purchase of 900,000 Gold Coins would also entitle the player to 1,000 Sweepstakes Cash Credits with a denomination of US$10.\u201d (Id., p. 60). This is the same pricing methodology that was used by internet sweepstakes cafes operating throughout California in the early 2000\u2019s. See California Department of Justice, Bureau of Gambling Control, Law Enforcement Advisory No. 11<\/a>, Dec. 5, 2012 (noting that internet caf\u00e9 customers received sweepstakes \u201centries\u201d or credits\u201d based upon the amount spent, e.g., 100 sweepstakes entries for $1.00 of Internet time purchased.\u201d).<\/p>\n According to the prospectus<\/a>, the Social Sweepstakes sector \u201chas experienced a strong rate of early adoption in the United States.\u201d (see pp. 18 & 66). \u201cSweepstakes gameplay facilitates a cash prize gaming experience in markets where online gambling may be prohibited,\u201d the prospectus<\/a> candidly acknowledges. (Id., p. 60). \u201cThe United States market is largely unrealised from the perspective of servicing players seeking a cash prize online gaming experience and this presents a strong growth opportunity for VGW Holdings as it seeks to increase its share of the US online gaming market,\u201d the prospectus<\/a> adds. (Id., pp. 18 & 66). The prospectus<\/a> then refers \u201cprospective investors\u201d to the H2 report which points to the success of \u201cInternet Sweepstakes Cafes\u201d as a \u201cland-based\u201d example that is \u201cequally applicable as a business model\u201d to \u201cInternet Sweepstakes Gaming.\u201d (Id., pp. 66 & 95-97). Based on the proliferation of internet sweepstakes cafes across the US over the preceding 10 years and the \u201clargely unrealised\u201d online component, the H2 report concludes that the real money \u201cinternet sweepstakes\u201d segment of the US gaming market \u201cremains strong, with considerable further growth still to come over the next 5 years to the end of the decade.\u201d (Id., pp. 18, 66, 68 & 98).<\/p>\n The timing of the prospectus may be problematic for VGW in California<\/p>\n It remains a mystery why VGW would have touted \u201cinternet sweepstakes cafes\u201d as an \u201cequally applicable\u201d business model for online sweepstakes casinos (such as Chumba Casino and Luckyland Slots) at a time when California had already declared such businesses to be illegal. Of course, the prospectus was obviously not drafted with just one state in mind \u2013 albeit, one which is considered the Holy Grail<\/a> of U.S. gaming markets. But that is some colossal oversight by VGW \u2013 especially now as the company makes the rounds in California and urges a legislative body which outlawed internet sweepstakes caf\u00e9s some ten years earlier to not ban the online analog of the same business model (at least according to VGW\u2019s 2016 prospectus).<\/p>\n The favorable comparisons to internet sweepstakes caf\u00e9s drawn throughout the prospectus dovetail with recent reporting by The Australian Financial Review. In a March 2024 profile<\/a> of VGW\u2019s founder Laurence Escalante, AFR associate editor and investigative reporter Primrose Riordan<\/a> interviewed the company\u2019s former chief operating officer, Ben Reichel, who told her that \u201cLaurence came up with the idea to use sweepstakes laws in the US to replicate online casinos and slot machines, as at the time you couldn\u2019t get a license for online gambling. It was a brilliant idea, people were keen to have an online gambling experience.\u201d<\/p>\n The AFR profile addresses the similarities to internet cafes, with Ms. Riordan writing that \u201cin meetings, Escalante and company executives had discussed internet caf\u00e9s in Florida that had managed to avoid restrictions on gambling by offering so-called sweepstakes games with chances to win prizes if customers purchased access to onsite computers.\u201d (Escalante denied<\/a> that Florida\u2019s internet caf\u00e9s were the \u201cinspiration\u201d for VGW, calling it a \u201ctotal fabrication.\u201d).<\/p>\n Artificial separation of \u201cconsideration\u201d from the chance to win real money<\/p>\n The similarities, however, cannot be ignored.<\/p>\n Online sweepstakes casinos use a similar pricing structure to disguise or mask the payment, also known as \u201cconsideration.\u201d For context, many states\u2019 anti-gambling laws (including California\u2019s) define an illegal lottery as comprised of three essential elements: prize, chance, and consideration (i.e., payment). Sweepstakes promotions typically possess two of the three characteristics of a lottery: chance and a prize. Therefore, to avoid classification as an illegal lottery, a valid promotional sweepstakes must not involve the payment of any consideration.<\/p>\n Online sweepstakes casinos attempt to sidestep the element of consideration by using a two-tiered system<\/a> of virtual coins. The first type of virtual currency \u2013 called \u201cGold Coins\u201d \u2013 can be used to play \u2018casino-style\u2019 games (such as slots, roulette, blackjack and poker) in a \u201cstandard mode\u201d with no potential for redeeming any prizes. The second type of virtual currency \u2013 typically called \u201cSweeps Coins\u201d \u2013 can be used to play the same games in a \u201cpromotional sweepstakes mode,\u201d where they carry real monetary value and can be redeemed for prizes and money. Players may switch between these modes easily and as frequently as they would like.<\/p>\n While there are several ways for players to receive Sweeps Coins for free, the most common way to obtain Sweeps Coins beyond a nominal amount is by purchasing Gold Coins. The more Gold Coins that a player purchases, the more Sweeps Coins the player also receives. Critically, the number of Sweeps Coins received as a free \u201cbonus\u201d corresponds with the amount of real money spent. There is essentially a 1:1 correlation<\/a> between the number of dollars spent and the number of Sweeps Coins provided in each purchase. The same rate of exchange applies when it\u2019s time to cash out as well. Sweeps Coins are redeemable at a conversion rate of 1:1<\/a>.<\/p>\n This is the same construct that was used by \u201cInternet sweepstakes caf\u00e9s\u201d in the early 2000\u2019s to offer real money casino-style gambling under the guise of a sweepstakes promotion. These operations \u2013 often located in suburban strip malls \u2013 \u201cpromoted\u201d the sale of products such as Internet access time or long-distance telephone minutes by offering \u201cfree\u201d sweepstakes entries to customers. When customers purchased the product, they received a corresponding number of \u201csweepstakes\u201d points for each dollar spent. (Typically, for every $1 dollar spent, the customer would receive 100 sweepstakes points<\/a>). Customers then used those sweepstakes points to play \u201ccasino-style\u201d slot machine games for cash prizes redeemable at a value of one cent per point<\/a>. In other words, $1 dollar in and $1 out. Just like the internet caf\u00e9s, online sweepstakes casinos artificially separate the consideration from the chance to win real money by claiming that the payment is for a \u201cproduct\u201d (i.e., Gold Coins) and the sweepstakes entries (i.e., Sweeps Coins) are \u201cfree,\u201d while conveniently providing the purchaser with a \u201cbonus\u201d allotment of Sweeps Coins that is nearly equivalent in value to the Gold Coin purchase price.<\/p>\n Indeed, the Louisiana Attorney General recently declared<\/a> that online sweepstakes casinos \u201care utilizing the same concept that was used by \u2018Internet sweepstakes cafes.\u2019\u201d She was referring specifically<\/a> to the 1:1 pricing formula in which website users \u201cmay purchase \u2018Gold Coins\u2019 and receive free \u2018Sweeps Coins\u2019 \u2018as a bonus,\u2019 typically in the same dollar amount as the purchase, which can then be used to play casino games and be redeemed for cash or valuable prizes.\u201d As the Attorney General explained<\/a>, \u201cthese online operators are attempting to artificially separate the consideration from the chance to win real money. However, disguised and\/or indirect consideration is still consideration and constitutes illegal gambling.\u201d<\/p>\n Courts throughout the United States have repeatedly determined that such tactics were an obvious pretext and cover for illegal gambling. For example, in Telesweeps of Butler Valley, Inc. v. Kelley, a Pennsylvania federal district court held<\/a> that the purchase of a long-distance telephone card that comes with a commensurate number of free entries to participate in a \u2018casino-style\u2019 sweepstakes games for prizes constituted \u201cindirect consideration\u201d to participate in the sweepstakes, even though no purchase was necessary and several alternative methods of free entry were available. In rejecting the defendant\u2019s argument that the customer was simply paying for long-distance telephone calling minutes and not the sweepstakes entries, the district court declared<\/a> that \u201cplaintiff\u2019s attempt to separate the consideration from the chance to win by inserting a step between the two elements is clever, but it merely elevates form over substance. At bottom, what Telesweeps is doing constitutes gambling.\u201d<\/p>\n Similarly, in Lucky Bob\u2019s Internet Caf\u00e9, LLC v. California Dep\u2019t of Justice, a California federal district court found<\/a> consideration to exist where customers were given 100 free entries to a \u201csweepstakes\u201d for every $1 of purchased internet time and played casino-style games of chance to find out whether they won a prize. The fact that customers could also obtain free entries without a purchase did not change the result. Citing prior California appellate court rulings, the court held<\/a> that \u201cthe consideration element is satisfied when some customers by chance receive more than what they paid for. . . . Once the elements of chance and prizes are added, the consideration paid is no longer solely for internet time. Paying for the chance to win money, rather than the use of Internet time, may be the customer\u2019s main focus.\u201d<\/p>\n In rejecting a similar sweepstakes scheme in Cleveland v. Thorne, the Ohio Court of Appeals explained<\/a>, \u201cthe justice system is not some lumbering oaf who must ignore the patently obvious gambling scheme apparent here simply because of a contrived separation between consideration and the scheme of chance.\u201d The court declared<\/a> that \u201cthe law in this arena serves no purpose to elevate form to such a high degree that the nature of the transaction should be ignored,\u201d adding<\/a> that \u201cthere is no justification for ignoring the nature of the transaction simply because the system is designed in such a way as to artificially isolate one part of the illegal transaction from another. The justice system is not so blinded by chicanery.\u201d<\/p>\n As the South Carolina Attorney General put it, \u201ca gambling scheme cannot be transformed into legitimacy merely by splitting it into two parts<\/a>. . . . To try and conceal gambling behind the fac\u0327ade of the purchase of Internet time is . . . nothing more than legal trickery.\u201d<\/p>\n Other parallels between online sweepstakes casinos and internet cafes<\/p>\n In addition to the nearly 1:1 correlation between money spent and Sweeps Coins received \u2014 a pricing structure which indicates that Gold Coins are merely a \u201ccover\u201d for the purchase of Sweeps Coins \u2014 there are several other factors which show that the true purpose of the sweepstakes casino websites is gambling, and that just like the Internet sweepstakes cafe\u0301s which preceded their launch, the use of the term \u201csweepstakes\u201d is a pretext for gambling.<\/p>\n First, the \u2018casino-like\u2019 atmosphere and imagery associated with the sweepstakes casino websites, as well as the aggressive online advertising<\/a> which is carefully crafted to exploit the appeal of gambling and is frequently loaded with images of people holding outsized checks indicating how much money they won gambling on the websites, suggests that the \u201ctrue purpose\u201d of the business is to promote sweepstakes play, as opposed to a good or service.<\/p>\n For example, in United States v. Davis, the United States Court of Appeals for the Fifth Circuit, applying Texas law, pointed<\/a> to the \u201ccasino-like atmosphere\u201d of the Internet caf\u00e9s \u2013 \u201ccomplete with tinted windows and free food and drink\u201d and \u201ca variety of casino-like games available on each computer terminal\u201d \u2013 as persuasive evidence that \u201cthe defendants\u2019 true purpose for the caf\u00e9s was to create a place where people would be comfortable staying for a long time, purchasing Internet time and playing the sweepstakes.\u201d Based on this evidence, the Fifth Circuit concluded<\/a> that \u201cthe main purpose and function\u201d of the business \u201cwas to induce people to play the sweepstakes, and that the Internet time sold by the caf\u00e9s\u2014albeit at fair market value\u2014was not the primary subject of the transaction, but instead mere subterfuge.\u201d<\/p>\n As the California Court of Appeal for the Second District appropriately observed<\/a> in People ex rel. Lockyer v. Pacific Gaming Technologies, in referring to a slot machine-style sweepstakes promotion, \u201cif it looks like a duck, walks like a duck, and sounds like a duck, it is a duck.\u201d<\/p>\n Second, the duration of the \u201csweepstakes\u201d promotion also demonstrates that the true purpose of the website is not to promote a bona fide consumer good or service, but instead gambling. A traditional sweepstakes promotion \u201cis a limited term event designed to attract consumer attention to a product or business, and ordinarily expires after a few weeks or months<\/a>.\u201d By contrast, sweepstakes casinos offer real money casino-style sweepstakes games perpetually.<\/p>\n In an opinion<\/a> issued last month, the Louisiana Attorney General pointed<\/a> to the \u201cperpetual duration\u201d and \u201congoing nature\u201d of the casino-style sweepstakes games as an indicator that the \u201ctrue purpose\u201d of online sweepstakes casino websites was to promote illegal gambling.<\/p>\n Third, the typical payout percentage for a temporary promotional sweepstakes is \u201ca trivial share of the revenue earned by the company<\/a>.\u201d For example, the typical grand prize for McDonald\u2019s annual Monopoly-themed sweepstakes is usually about $1 million, which is a tiny fraction of the billions of dollars McDonald\u2019s earns each year. By contrast, commercial casinos typically pay out between 80-96 percent of their revenues (sometimes referred to as the \u201creturn to player\u201d or \u201cRTP\u201d). Chumba Casino claims to have a 90-96% RTP on its website.<\/p>\n Fourth, conditions designed to keep users playing the sweepstakes games for a longer period of time and, consequently, spending more money to facilitate sweepstakes play are indicative that the true purpose of the business is to promote sweepstakes play, as opposed to a legitimate good or service. Unlike traditional sweepstakes games where prizes can be claimed immediately, many online sweepstakes casinos have a \u201cminimum permitted redemption<\/a>\u201d threshold that limits a user\u2019s ability to redeem prizes unless their Sweeps Coins balance is above a certain amount. In most cases, the minimum redemption threshold is 100 Sweeps Coins. Thus, if a user never reaches 100 Sweeps Coins won, he or she can never redeem anything. This causes consumers to continue gambling and eventually lose their balance.<\/p>\n Fifth, many of the users of the websites largely ignore their ample supply of Gold Coins in favor of playing Sweeps Coins, which is a clear indication that the Sweeps Coins, and not the supposedly promoted product (Gold Coins), are the primary subject of the transaction.<\/p>\n The available evidence strongly suggests that online sweepstakes casino spenders are far more interested in the Sweeps Coins that are included as a \u201cbonus\u201d item when they purchase Gold Coins. An online survey<\/a> conducted by the American Gaming Association in June found<\/a> that, among players who spend money on these platforms, 67% said that they were \u201cprimarily interested\u201d in obtaining the Sweeps Coins rather than the Gold Coins, emphasizing the appeal of the tokens with redeemable cash value. Of these spenders, 76% said<\/a> Sweeps Coins were either \u201cvery\u201d or \u201cextremely important\u201d in deciding whether to buy a package of Gold Coins.<\/p>\n In sum, the parallels between the \u2018dual-currency\u2019 online sweepstakes casino websites and the Internet cafe\u0301 business model\u2014which courts have held are incontestably gambling\u2014are clear:<\/p>\n Both sell a \u201cproduct\u201d that comes with a commensurate number of \u201cfree\u201d sweepstakes entries to play real money \u2018casino-style\u2019 games of chance in a \u2018casino-like\u2019 setting. Instead of the cafes selling a prepaid phone card or internet access time, the online sweepstakes casinos sell a nonredeemable \u201cvirtual gold coin.\u201d). Given these striking similarities and the frequent references to the \u201cinternet sweepstakes cafe business model\u201d in its 2016 prospectus, VGW seems like an odd (if not downright puzzling) choice to lead the opposition to Assembly Bill 831. In essence, a company which once compared itself to internet sweepstakes cafes and is seemingly deploying a similar business model is tasked with convincing a legislative body which previously outlawed internet sweepstakes cafes to do an about face and not only refrain from banning the online versions of the same games but to regulate them instead. That seems like an especially tall order in light of California\u2019s continuing crackdown<\/a> on internet cafes and its ongoing tribal compact<\/a> obligations which guarantee Native American tribes exclusivity over casino-style gaming.<\/p>\n","protected":false},"excerpt":{"rendered":"3d illustration of laptop over white background with blue reflection screen and slot machine getty California has easily…\n","protected":false},"author":2,"featured_media":120989,"comment_status":"","ping_status":"","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[43],"tags":[2205,15361,15363,559,174,77641,77640,77639,74,77643,77644,77642],"class_list":{"0":"post-120988","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","7":"category-internet","8":"tag-betting","9":"tag-casino","10":"tag-gambling","11":"tag-gaming","12":"tag-internet","13":"tag-roulette","14":"tag-slot-machine","15":"tag-sweepstakes","16":"tag-technology","17":"tag-tribes","18":"tag-vgw","19":"tag-wagering"},"_links":{"self":[{"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/posts\/120988","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/comments?post=120988"}],"version-history":[{"count":0,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/posts\/120988\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/media\/120989"}],"wp:attachment":[{"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/media?parent=120988"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/categories?post=120988"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.newsbeep.com\/us\/wp-json\/wp\/v2\/tags?post=120988"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\n Both run sweepstakes games perpetually and not on a limited and occasional basis, as is typical with legitimate promotional sweepstakes such as those offered by McDonald\u2019s or Starbucks;
\n Both offer casino-like payouts, typically 90% or more of revenues, whereas legitimate promotional sweepstakes normally have very low prize to entrant ratios.
\n Both offer several ways to get free entries without requiring a product purchase, such as by mailing a postcard to a designated P.O. Box address (although the number of free entries awarded through this method is usually a very low amount).<\/p>\n