Whatever you might be thinking, it just means "I Am Not A Lawyer".
And I am not a lawyer. My earlier post It isn't gambling addressed why a penny auction is not a game of chance and my co-blogger wrote about how large VC firms were investing in penny-auction sites and reasoned that they pay for good lawyers and wouldn't invest in anything that was likely to land them in jail.
It's not legal advice, though. I'm too cheap to pay for real legal research, so I looked around, yes, the Internet, and here's what the great state of California, where I am lucky enough to reside, has to say:
California law prohibits lotteries. A lottery is any scheme for the disposition of property by chance among persons who have paid or promised to pay any value for the chance of obtaining the property, with the understanding that it will be disposed of by chance. [emphasis added]If I were a lawyer, I might think that since penny auctions lack the element of chance, they aren't lotteries.
But I Am Not A Lawyer.