Laws do not work that way!
[You don't get to use a Morbo reference every day on Hacker News.]
[You don't get to use a Morbo reference every day on Hacker News.]
having no specific knowledge about sweepstakes regulations, i does not appear completely unreasonable to me that a random drawing in each territory completely changing the outcome might satisfy the requirements.
as a practical matter, when $1m in extra payouts are at stake it could be reasonable to accept a fine from regulators while at the same time avoiding civil liability to participants.