I think the traded for something angle is key here. And, of course, SEC is generally happy when consumers benefit, and fines when they don't. But, I would thin

I think the traded for something angle is key here. And, of course, SEC is generally happy when consumers benefit, and fines when they don't. But, I would think a line of defense would be that participants knew they wouldn't necessarily get anything for participating and presumably agreed to that in contest terms. At that point, the contest is just a giveaway -- and you can, in fact, give away stock.