At the crux of the Ironman investigation was the lottery fee (between $35 – $50/person) the WTC required to enter the lottery. In reaching the settlement, the WTC Complaint concluded that ‘probable cause exists to believe that the Lottery Proceeds are traceable to proceeds of an illegal gambling business because each lottery included a prize (the entry slot); random drawing; and consideration ($35-50/person).’
In fact, shortly after the Ironman folks down in Florida got nabbed, their largest competitor rolled out a multi-faceted lottery promotion called Roth Rewards. One of the Roth Rewards’ lottery requires the athlete complete Challenge Cedar Point Full 2015 in order to be eligible to win the race lottery slot.
Under lottery case law, it’s almost universally established that consideration exists where the purchase of a product or service is required to enter the random drawing with no alternative free method of entry.
[...] one could easily make a compelling case that by requiring an individual to register and pay for another Challenge-branded event, this also amounts to consideration making the lottery illegal.