I actually meant to do this last year's campaign, but now that it's up and running again, I am deathly curious how local grocery store chain Ukrops argues the legality of their annual Brand Bonanza contest. You can read the two FAQs for more information, but here, in short, is how the contest works: Every time you buy a Ukrop’s-brand product with your Ukrop’s card, you receive one entry into the contest. (There is a "No Purchase Necessary" clause: You can submit an entry by mailing them a 3” x 5” card with your handwritten name, address, Ukrop’s Card number and telephone number.)Each week, five entries are chosen at random, and the entries are ordered by the number of Ukrop’s-brand items purchased over a certain period of time. The "Ukrop’s Brand Gang" first visits the house of the customer who (of the five entries) purchased the greatest number of Ukrop’s brand items. The "Brand Gang" counts the number of Ukrop’s brand items the customer has on-hand, multiplies that number by $200, and gives the customer that amount of money. If the amount of money they gave out was less than $3000, the "Brand Gang" goes on to the house of the customer who (of the five entries) purchased the second-greatest number of Ukrop’s brand items, continuing on until (a) they've visited all five customers or (b) they've given out at least $3000.

Now. For one point each, list and explain a potential legal problem in their campaign. (I've thought of at least three.)