It pays to be very clear here. The advertising is listed above with a 3-5* guarantee of any class w a chance to win an X-mas soul. Every soul yields a 3* or better. Some souls are christmas characters (I and others have them as proof). Thus, the adverising is true.

Where we have an area regarding deception is that (as far as I am aware) there have been no honest representations of the odds. Consider these hypothetical odds:

3:4 3* magus/sentinel/warrior
1:10 3* gunner/assassin
1:100 4* any class
1:1,000 5* any class
1:100 3* X-mas toon
1:10,000 Coalgiver Eddie

If these were factual, if these were disclosed, and if one had a soul motivation (pun) to spend $/resources for coalgiver, advance disclosure may dissuade any gamble or expenditure of resources given 1:10,000 odds. Concealing these odds is the deception.

We all know there is a lottery system, but none knows how narrow the odds are. This is the idea in contracts where the meeting of the minds are required for a valid transaction. If one spends under the impression that a game of chance is 1:100 but the odds really are 1:50,000, there is no meeting of the minds. This is what is problematic about this game for me, and it may/may not have future ramifications down the line.

lotteries have posted prize odds. There was earlier discussion of China requiring these games to post odds for similar reasons. This is where the point of contention lies... not from "false advertising" but "deceptive advertising" (the willful concealment of known odds on the basis that publication may negatively affect sales).