How much is a “lifetime’s supply” of gumballs? According to a recent sweepstakes from Gumball.com, the answer is exactly 22,082.5 gumballs.
Promotions like this, where entrants can win a lifetime supply of a particular product, made us stop and think about what these winners actually receive. As with any sweepstakes or contest, companies must disclose certain information about the nature of the prize being offered. Advertisements must be accompanied by a disclaimer defining exactly what that supply entails: how much it is, its retail value, when and how it will be delivered to the winner, and whether the winner must meet any requirements to receive the prize. Companies must also adhere to the FTC’s generally-applicable “reasonableness test” which in this case, requires a reasonable person to agree that the amount awarded would last an average individual for the time period stated.
Without further guidance, companies have license to get a little creative. For the Gumball.com promotion, the company took the average life expectancy of a U.S. citizen, subtracted it by 18 (the minimum age of entry) and multiplied the difference by 365, representing one gumball per day. Avoiding a mathematics-induced headache, some promotions simply state a number without providing any explanation. For example, a Center for Biological Diversity giveaway offered its five winners a “lifetime supply” of 10,000 condoms. We’ll let you decide whether you think that’s reasonable.
The same standard applies to contests offering winners a “year’s supply” of a product. In these cases, companies usually calculate the prize based on average daily or weekly consumption of the product. For instance, Starbucks defines free coffee for a year as 52 10-count packages of K-Cups, while Hy-Vee, a Midwestern grocery chain, gave away 365 Tide Pods for winners to wash a year’s worth of laundry.
Winning a lifetime supply does not necessarily mean you should expect boxes upon boxes of the product to show up at your door. To avoid a potential logistical nightmare, some companies elect to offer coupons redeemable in stores for the product. In a VH1 sweepstakes offering the grand prize winner a lifetime supply of Burger King, the winner actually receives a $500 gift card every 6 months for the next 25 years. ClickInks.com sends winners a voucher for $100, its equivalent of a year’s supply of printer ink.
For companies looking to promote their next “lifetime supply” giveaway, the answer is clear – use a reasonable means to calculate your prize, and then disclose those methods in your contest rules. For consumers, all you need to do is make room in your home for 22,000 gumballs.