Letter Headed Legal Statement

General information for the business: Prize Compeition
Industry: Entertainment
Legal topic: Letter
Description of legal work: I need an independent legal opinion stating why my business concept is classified as a prize competition (as opposed to a gambling site or lottery). This must be letter headed.
Extra notes: I am currently integrating payment platforms onto my website. The letter headed confirmation is for a payment service provider (Pay Pal) who want an independent legal opinion to show that the website is a prize competition (section 14(5)(a), Gambling Act 2005).

Pay Pal's exact request:
- Provide an independent legal opinion stating why the games available on http://www.photopunt.com/ (my website) are not considered gambling activities in the jurisdictions they are offered. Please note that this document must be letter headed.

I've attached an overview of the business concept and the applicable law (from my unqualified point of view!).