The Court held that referral sales programs of the type in question do not constitute illegal lotteries under Idaho Law. An illegal lottery must give a return based solely on chance in Idaho. Cen-States Marketing sold stereos door-to-door. Purchasers also were given the opportunity to earn commissions based on referrals of other prospective stereo purchasers sent to Cen-States. Because there was skill involved in the selecting and referring of prospects and it was not purely by chance, the sales program was not an illegal lottery.
This case can also be found at: http://www.mlmlegal.com/legal-cases/Braddock_v_Family_Finance_corp.php.
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