This could be construed as true if there was anything bought/sold. Might want to do your homework on regulations on free giveaways or in other words "Donations" (Charities etc.).... Any sort of donation is TAX FREE =)
So now you want to call this a donation to the charity of Silicon Valley? You guys will say anything to try to justify this crap!
WTF?? It's common sense, darling. Really. Do your research man hahaha.