Due to the apparent confusion caused by my post, I will try again.
They key is considered exploited, I do not know the reason behind that so I can't tell you why it is considered exploited, however the reason for it being marked exploited doesn't matter, all that matters is that it is considered exploited and therefore not allowed. You would need to go through cg to get permission to give it away, and would also need cg to adjust your giveaway so you could give away that many.
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Also I would love the chance to win a copy of it if you do get permission to give it away.
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I want to create a distribution of 50 copies of the game Puzzle Agent? Need?
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