Trying to stear clear of "Raffle" designation

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nowayjose

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Hello all! First time poster :)

I have a sizeable Facebook fan base(15k+) and have hooked up vendors/manufacturers to do some contests with some different products. Our facebook page is centered around a petition drive on a local mall(won't get in to details). We've set up a donation page on a 3rd party site that accepts donations for companies and individuals alike.

Our plan is to have folks donate $1 to our petition cause. For each donation, the donor will receive a voucher #(akin to a raffle ticket). At the end of the time period, we'll randomly pick a winner for the product.

Yes, yes....it sounds EXACTLY like a raffle....but here's the twist:

We've offered a 2nd FREE way to enter the raffle, so that it's not required for a participant to come up with any "consideration" to enter the drawing. This 2nd free way to enter takes more of an an effort(by getting off their butt and going to their local State Rep's office), but is still wide open for anyone to utilize.

ALSO, for ever donation made, we're sending a photo file to the donor. We've assigned a $1 value to this photo. The donor's are essentially receiving something of value in return for their giving.

Are we covering our butt adequately?

Thanks in advance, for your time!
 
It all depends on what a prosecutor or attorney general thinks. I think you're heading for trouble.


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I believe you probably should have ran this by an attorney before setting it up.
 
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