It is a bit more complex. OP may possibly try to give away the freebie Pixel Puzzles 1: Japan standalone game, which would give the winner the Puzzle Pack: PP1 Japan DLC for PP Ultimate. It is a loophole, but at least conforms the rules to a degree. But the Puzzle Pack Japan DLC is a set of different pictures. So, if this really is the free game, then the winner won't get this particular DLC. And since this is level 0 and the chance for the winner to actually see what he activates (most just mindlessly hoard games without ever looking at the key unless it returns an error), said winner may never know that he never received the actually promised DLC.