I think legally you are wrong. In the "legal" sense time is not valued. Retail chains always run these contests or drawings. Notice they always say "no purchase necessary". This is a legal requirement so you're not risking anything of value (money) to enter making it gambling. Time is not considered and I have a feeling that if there was a court challenge to this it would fail. I do believe this is a scam however (but patron beware).
···
Sent from my iPhone