You might want to make a call to the AR State Attorney General and see want they think and how the application of State law would impact this promotion. I think it is violation as the entrants are required to be customers.
5-66-119. Lottery - Promotion through sales.
(1) Any person who in this state, directly or indirectly, sets up, promotes, engages in, or in any manner participates in any plan, scheme, device, or other means, either alone or in concert with any other person, firm, or corporation, either within or without the State of Arkansas, in which goods, property, or any other thing of value is sold to any person, firm, or corporation for any consideration, either cash or otherwise, and upon the further consideration that the purchaser agrees to obtain one (1) or more persons to participate in the plan, scheme, device, or other means by making a similar purchase and a similar agreement to secure one (1) or more other persons to participate in the plan, scheme, device, or other means in the same manner, each purchaser being given the right to obtain money, credits, goods, or some other thing of value, depending upon the number of persons joining in or participating in the plan, scheme, device, or other means, is declared to have set up, promoted, engaged in, or participated in a lottery, which is declared to be unlawful.
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