You know, I had a friend arrested in Texas for selling 20$ handshakes and giving out free bottles of mead as gifts for meeting 'the viking'.
In a court of law, those stated practices are gambling son. It's still a monetary transaction, regardless of whether or not it is a 'gift'. Not to mention highly unethical for a corporation to be abusing its consumers by making incentives for 'gifts', despite the monetary purchase being for another item and purpose entirely.
- - - Updated - - -
And eventually, his bail when he gets arrested for illegally gambling over the internet.