Chipotle Halloween Sweepstakes Promotion and the Law

After a two-year hiatus, Chipotle is bringing back the Boorito Halloween Sweepstakes promotion, but this time by partnering with BeReal. For those who do not know, BeReal is a photo sharing application, designed to instill a sense of spontaneity in a user’s posting of, in-the-moment, “real” photos. According to the website, “[e]veryday at a different time, everyone is notified simultaneously to capture and share a Photo in 2 Minutes.” The joint venture between Chipotle and BeReal focuses on a Boorito Sweepstakes event. And as we have discussed in earlier blogs, certain fundamental provisions must be included in any legitimate sweepstakes promotion. 

General Requirements to Set up a Sweepstakes Promotion

Companies offering consumers the opportunity to enter a sweepstakes promotion, must follow applicable laws and regulations. Chipotle’s Halloween Sweepstakes contest is no exception. The provisions should include, among other things, the promotion’s duration, entry eligibility details, winner selection process, prize amounts, number of available prizes, and a free alternative means of entry (“AMOE”). As for this last category, Chipotle’s BooReal Sweepstakes Official Rules indicate in “all caps” that there is: “NO PURCHASE NECESSARY.  A PURCHASE WILL NOT IMPROVE YOUR CHANCE OF WINNING.” Clearly, there is a free AMOE! See below for the AMOE.

Specific Requirements to Enter Chipotle’s Halloween Sweepstakes Promotion

Because this Sweepstakes is a joint effort between a burrito chain and a social media photo-sharing app, the methods to enter are particularly unique. There are two ways to enter: (1) By Posting a Photo during the Promotion Period (beginning October 31, 2022 at 12:01 a.m. Pacific Time (“PT”) and ending on October 31, 2022 at 11:59 p.m. PT), eligible entrants must: (i) take an original photo in costume at a Chipotle restaurant on 10/31/22 using the BeReal app; (ii) post the Photo on the entrant’s BeReal account with the hashtag #BooritoSweepstakes; and (iii) share the Photo to the entrant’s Instagram account through the BeReal app tagging @chipotle and  using the hashtag #BooritoSweepstakes; or (2) Without Making a Post (this is their AMOE): During the Promotion Period, each would-be participant may send an e-mail to with his or her name, age, address, telephone number and e-mail address. Entrants must write “BooReal Sweepstakes” in the e-mail subject line. The sweepstakes rules also limit entry to one per eligible entrant during the Promotion Period, regardless of the method of entry.

The rules specify that there are ten prizes available. Each prize consists of one “Burritos for a Year Prize,” which consists of Chipotle Rewards credits good for one (1) free burrito entrée per week for a year, or a total of up to fifty-two (52) burrito entrées. The remainder of the contest rules specify eligibility, winner selection and notification, and other additional provisions. 

Chipotle’s Exciting BooReal Halloween Sweepstakes Game Attracts Customers!

A sweepstakes promotion is a creative way to advertise a company’s products and services. Additionally, when set up correctly and within the confines of applicable laws, sweepstakes can be an effective way to both reach new clients and retain existing ones. As always, we cannot stress enough the importance of creating a legal contest. The best way to achieve this goal is to consult with experienced promotional law and sweepstakes attorneys.

If you are interested in learning more about this topic or require assistance in connection with putting together an sweepstakes promotion, please e-mail us at, or call us at (212) 246-0900.

The material contained herein is provided for informational purposes only and is not legal advice, nor is it a substitute for obtaining legal advice from an attorney.  Each situation is unique, and you should not act or rely on any information contained herein without seeking the advice of an experienced attorney.

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Photo by Rosalind Chang on Unsplash

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David Klein

David Klein is one of the most recognized attorneys in the technology, Internet marketing, sweepstakes, and telecommunications fields. Skilled at counseling clients on a broad range of technology-related matters, David Klein has substantial experience in negotiating and drafting complex licensing, marketing and Internet agreements.

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