Not a lawyer, but I think this doesn't qualify as gambling from a legal perspective. Prizes with odds is not a sufficient condition - it has to be that the 'bet' is a stake that you can (and probably will) lose. If the worst case outcome is that you get something back of comparable value to the money you put in, then you are not gambling your money. It's like a door prize at a concert - you paid for a ticket, the door prize doesn't make it a casino. Anyone who enters a blue box to get a prize other than the default iems is a dummy. If you feel like gambling $20 at 1 / 100 or 1/1000 odds you can way better winning payouts than are on offer here.