Alll of the esteemed lawyers on list can offer their opinions on this but the only opinion that really matters is the one sought by ICANN legal. 

Would be good to know if that is in process or has been completed and what it ultimately allows. 

On Aug 30, 2024, at 8:47 PM, Anne ICANN via SubPro-IRT <subpro-irt@icann.org> wrote:


I am not a CA lawyer but I think the exception relates to the nature of the entity conducting the raffle, not just the question of where the proceeds go. 
Anne

Anne Aikman-Scalese
GNSO Councilor
NomCom Non-Voting 2022-2024


On Fri, Aug 30, 2024 at 3:28 PM Rubens Kuhl via SubPro-IRT <subpro-irt@icann.org> wrote:


Em 30 de ago. de 2024, à(s) 19:21, <trachtenbergm@gtlaw.com> <trachtenbergm@gtlaw.com> escreveu:

With respect to California’s lottery laws, there is an exception permitting charities and certain other private nonprofit organizations may conduct raffles to raise funds for beneficial or charitable purposes in the state.  But this exception to the general constitutional prohibition against lotteries requires that at least 90 percent of the gross receipts from these raffles go directly to beneficial or charitable purposes in California. Seehttps://oag.ca.gov/charities/raffles .  I don’t this would qualify.
 

Making 90% of USD 100 * 1500 applications = USD 150k go to charitable purposes is very easy to do, if that’s all that’s required. 


Rubens



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