Publish America's modus operandi is very similar to Publishers Clearing House Sweepstakes (that's probably where they got the idea). PCH offers the chance to win a large amount of money, while stating that it is not required to buy their magazine subscriptions to win, or intimating to the person opening the envelope that they have already won, all they have to do is enter, knowing in the short run that they will sell magazine subscriptions to those hoping to enhance their chances of winning big bucks.
PA plays on the same type emotion of intimating to writers that they have an excellent chance of success is selling their books, if they will only enter (give up their manuscript), while all the time they plan on selling authors their own books.
Note: While I was typing the above, a message popped up on the bottom of the screen informing me I had an email from Publishers Clearing House (this is true), subject: Last Chance to Win. I think I had better go and see what that is all about. I could use the money.