Legal Question in Technology Law in California

Law enforcement won't believe it's free, especially if prizes of any value are being given. They'll be looking for the consideration. I know that free prize operations have been deemed not free because you had to come to the store to drop off your ticket, or whatever. I guess having to visit the store was deemed consideration, since once you're there, you'll be looking at the merchandise and might buy something. I can't say what your risk is without studying the entire operation from top to bottom, but I'm sure it isn't zero.