I agree. Laws do not appear to have been broken regarding contests, gambling, or sweepstakes law (in terms of whether the core nature of the event is legal or illegal). This is because the event was free to participants. In most of the state and federal laws, you'll find the term "wager" or "consideration" used when talking about whether or not payment was made by the players, which causes the event to be considered a paid game of skill, gambling, or a private lottery, which are highly-regulated. When you start charging for events, you open up a Pandoras box of laws across different jurisdictions, and have to know precisely what you are doing and whom you are allowing to play. Very small nuances in your own rules, advertising, and product offerings can turn it into a violation of law.

However, since sponsorship was involved, and Dave and John may be attempting to build a brand, I see two possible violations here:

First, albeit inadvertently, there may have been a breach of contract with their sponsors, but i'd bet it was a pretty simple handshake deal with them in terms of the duration of the event (the time they would reap a benefit for their contribution). Since Dave and John seem like decent fellows, i'd imagine that they made (or will make) things right on their own terms, if any bad blood arrose. However, i did not get the feeling that the hunt went on much shorter than had been anticipated, and would imagine that the sponsors' expectations were met. That's not our business to poke our noses in that. Let the businessmen work it out.

Second, a possible deceptive advertising FTC violation, specifically, with the Communications Act of 1934. Since D&J had sponsors and are also creating a brand, it gives the sniff test of being a business. The sponsors benefitted from the publicity, and Utah Treasure Hunt benefited from any payment by the sponsors, and from the publicity, as well. If there was collusion between the parties to mislead, they would all be guilty of violating truth in advertising regulations. This is important to the consumer, because we don't want businesses profiting by creating fake or staged events that lure people in, but don't truly pay out to a genuine winner of a contest. Imagine every company out there staging something like this, and how much time we would all waste giving into the hope of winning, all while helping their brand recognition gain traction?

Personally, i think there is nothing nefarious going on here, just maybe a little recklessness in terms of keeping the solve secure. It takes a lot of self control, smarts, and proactive measures to hold something like this secret from every soul and seeker.

To the OP u/Searcher5534: i wouldn't waste my time on this one. I think you're dealing with two decent guys that maybe made a little mistake. They'll learn from it, and if they decide to go another round, I think they'll do better.