Is it though? IANAL, but I feel like this is, at the very least, a gray area.
You can't purchase anything. The ad didn't say anything except maybe "play now", and there is a game and it may even contain a mini game of sorts that's kinda the ad.. The "harm" is like 3 seconds of your time. The "product" doesn't not do what it says because... It doesn't exist....
I dunno. Maybe it is. I feel like this is one of those things where "we all know it is" but "legally they probably wiggle their way out of the legal definition, and what are people going to do? Sue them for 5$?"
Not that I agree with it, don't get me wrong. I think we all know it's fucking scummy bullshit. But I'm not sure you'd win a court case over it and what harm you could argue it caused you etc.