I use the gift cards that I have collected across the year (either from contests or discount purchases) to bring little joys to the entire holiday seasons. Starting around thanksgiving, I send my kids dunkin or other coffee gift cards so their Black ...

I agree with you. I think they’ve set up each award opportunity as a separate sweepstakes.  It’s clear that each sweepstake is then governed by the sweepstakes laws of the FTC (which don’t really mean to micromanage every sweepstakes, but rather ensu...