Originally Posted by rrgg
It's easy to deceive customers with offers of gambling, which is really what the contest is. Therefore you have to offer a free gamepiece.
Precisely. There are three fundamental elements that are used to determine whether something constitutes gambling - chance, prize, and consideration. Offering the free gamepiece removes the element of consideration, since you then do not have to pay anything for the chance to win the prize.
In other words, were Cinemark to offer a contest only for their own customers - without the free gamepiece offer - they'd be in violation of lottery laws in all 50 states and Canada, as well as in violation of federal postal codes that forbid the usage of US mail to conduct an interstate lottery.
Mike