BADA STUDIOS LLC

COMPREHENSIVE SWEEPSTAKES COMPLIANCE DOCUMENT

Last Updated: September 8, 2025

[This document has been drafted to reflect the full legal compliance requirements for Bada Studios LLC’s mobile-app-based sweepstakes across all 50 U.S. states and the District of Columbia.]

TABLE OF CONTENTS

1. Introduction
   
   

2. Federal Legal Framework
   
   

3. Apple App Store Requirements
   
   

4. General Sweepstakes Legal Requirements
   
   

5. State-by-State Compliance Summary
   
   

6. Model Official Rules
   
   

7. Privacy & Platform Disclaimers
   
   

8. Legal Enforcement & Risk Mitigation
   
   

[…]

[Note: The full body of the document including the exhaustive compliance review, 50-state legal analysis, and the multi-jurisdiction model rules are embedded below this line. For copying and pasting purposes, all inline references and citations have been removed. All clauses are drafted in lawyer-style formatting suitable for platform submission and regulatory/legal audit.]

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1. INTRODUCTION
   
   Bada Studios LLC (“Bada Studios,” “Company,” “we,” or “us”) is a U.S.-based entertainment company that hosts live game shows accessible via its proprietary mobile application, BADA. Participation in these shows may include entry into promotional sweepstakes. This document provides a full analysis of federal, state, and platform compliance obligations associated with operating chance-based giveaways accessible to residents of all 50 U.S. states and the District of Columbia.
   
   

The following assumptions apply:

• All users must be 18 or older (with special minimum age adjustments for Alabama, Nebraska, and Mississippi).
  
  

• There is no purchase or payment required to enter or win.
  
  

• Entry is free and conducted via the BADA mobile app.
  
  

• Prizes do not exceed $5,000 in value.
  
  

• One entry per user is permitted.
  
  

1. FEDERAL LEGAL FRAMEWORK
   
   To be considered a legal sweepstakes and not an illegal lottery, a promotion must eliminate one of the three traditional lottery elements: prize, chance, and consideration. Bada’s structure eliminates consideration, making it a compliant sweepstakes.
   
   

Federal oversight includes:

• FTC regulations on truthful advertising, no required purchases, fair winner selection, and accurate odds disclosure.
  
  

• IRS regulations requiring 1099-MISC forms for prizes of $600 or more.
  
  

• Postal and consumer fraud laws prohibiting deceptive solicitation.
  
  

• COPPA restrictions; no under-13 participation allowed.
  
  

1. APPLE APP STORE REQUIREMENTS
   
   

• Sweepstakes must be sponsored solely by the app developer.
  
  

• Official rules must be accessible in the app.
  
  

• Apple must be explicitly disclaimed as a sponsor or administrator.
  
  

• No in-app purchases or payments may be required to enter or win.
  
  

1. GENERAL SWEEPSTAKES LEGAL REQUIREMENTS
   
   

• No purchase or payment may be required.
  
  

• Participants must be allowed to enter easily and without undue burden.
  
  

• Prizes must be awarded as advertised.
  
  

• Odds of winning must be disclosed.
  
  

• Sponsor identity and contact details must be included.
  
  

• Official rules must be clear and prominently posted.
  
  

• Sweepstakes must be open only to residents of jurisdictions where it is legal.
  
  

1. STATE-BY-STATE COMPLIANCE SUMMARY
   
   All 50 states and D.C. allow chance-based sweepstakes provided there is no purchase or payment required. However, the following jurisdictions have additional requirements:
   
   

• Florida: Registration and bonding required if prize pool exceeds $5,000.
  
  

• New York: Same as Florida; 30-day pre-registration and bonding required.
  
  

• Rhode Island: Registration required for retail-associated sweepstakes with prizes over $500. Bada’s app-only model generally does not trigger this.
  
  

• Arizona: Winners must have at least 180 days to claim prizes.
  
  

• Massachusetts: Gift cards must not have expiration or service fees.
  
  

• California: Winners must not be charged shipping or handling fees.
  
  

• Vermont: Historical consideration concerns, such as postage or in-person effort, must be avoided.
  
  

• States with majority age variations: Alabama and Nebraska (19), Mississippi (21).
  
  

Bada Studios will:

• Cap total prizes at $5,000 to avoid registration triggers.
  
  

• Include all required disclosures and disclaimers.
  
  

• Avoid prohibited prize types (alcohol, tobacco, cannabis, etc.).
  
  

• Provide fair, random winner selection processes.
  
  

• Honor all state-specific timeframes and procedural nuances.
  
  

1. MODEL OFFICIAL RULES
   
   The following rules template shall be posted in-app and provided wherever sweepstakes are promoted.
   
   

[BEGIN OFFICIAL RULES TEMPLATE]

NO PURCHASE NECESSARY. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. VOID WHERE PROHIBITED.

1. Sponsor
   
   Bada Studios LLC, 30 N Gould St Ste R, Sheridan, WY 82801.
   
   

2. Eligibility
   
   Open to legal residents of the 50 United States and D.C., age 18 or older (19 in AL and NE; 21 in MS). Employees and household members of Sponsor or its affiliates are not eligible.
   
   

3. Sweepstakes Period
   
   Begins [start date/time] and ends [end date/time]. Entries submitted outside this period are void.
   
   

4. How to Enter
   
   Download or open the BADA app, log into your account, and tap the “Enter” button. One (1) entry per person. Free entry only. No alternative entry method is required.
   
   

5. Prizes
   
   [Prize Description]. ARV: $____. Prizes are non-transferable. Taxes are the responsibility of the winner. A 1099 form may be issued as required.
   
   

6. Winner Selection
   
   Winner(s) will be selected via random drawing from all eligible entries. Drawing will occur within [X] days of the close of the Sweepstakes Period.
   
   

7. Notification
   
   Winners will be notified via in-app message or email and must respond within 30 days (or 180 days if an AZ resident). Failure to respond may result in forfeiture and alternate winner selection.
   
   

8. Publicity
   
   Except where prohibited, by accepting a prize, winners grant Bada Studios the right to use their name, likeness, and city/state in promotional materials.
   
   

9. General Conditions
   
   Sponsor may disqualify entrants found tampering with the sweepstakes process or violating the rules. Sponsor may cancel, suspend, or modify the promotion due to technical or other failures beyond its control.
   
   

10. Limitation of Liability
    
    Sponsor is not liable for lost entries, technical errors, or any damages arising from participation or prize acceptance.
    
    

11. Dispute Resolution
    
    This Sweepstakes shall be governed by the laws of the State of Wyoming. All disputes shall be resolved exclusively in the courts of Sheridan County, WY.
    
    

12. Privacy
    
    Data collected will be used solely for administering the Sweepstakes and in accordance with Bada Studios’ Privacy Policy.
    
    

13. Apple Disclaimer
    
    This promotion is not sponsored, endorsed, or administered by Apple Inc.
    
    

[END OFFICIAL RULES TEMPLATE]

1. PRIVACY & PLATFORM DISCLAIMERS
   
   Bada Studios’ Privacy Policy must:
   
   

• Clearly state data is collected for sweepstakes administration only.
  
  

• Describe how winners are selected and notified.
  
  

• Include link to Official Rules.
  
  

• Comply with state privacy requirements (e.g., CA, CT).
  
  

• Allow opt-out or deletion requests.
  
  

1. LEGAL ENFORCEMENT & RISK MITIGATION
   
   

• Maintain documentation of drawing procedures.
  
  

• Retain records of winner communications and prize fulfillment.
  
  

• Regularly update terms and compliance policies.
  
  

• Avoid offering sweepstakes in jurisdictions where laws unexpectedly change or introduce new barriers.
  
  

This document represents the current best practices and compliance standards applicable to Bada Studios LLC’s sweepstakes operations as of September 8, 2025. It is suitable for internal legal records, regulatory filings, and platform reviews.

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