The California New Car Dealers Association sent a letter of complaint to the Department of Motor Vehicle, citing the Tesla referral program as being set up to use unlicensed salespeople to further vehicle sales.

The practice, known as “bird-dogging,” caused the CNCD to expand already filed complaints. The association filed one in September 2013 and again August 2015, according to Automotive News. The DMV went as far as issuing a warning to Tesla in September of 2015.

The referral program is set up so that Tesla owners can refer their friends and reap the benefits after reaching different benchmarks of Model S and Model X referral sales. An app keeps track of each owner’s referrals, and there are prizes awarded at different levels.

Tesla teased in early August that “amazing adventures” would be gifted to top referrers. The announcement came at a separate Tesla referral presentation during the Model 3 delivery event where company representatives thanked the customers for almost 7,000 referral sales.

In 2015, the association complained about the referral program that offers a $1,000 discount off the price of a Model S and Model X to each recipient. In this instance, the CNCD is concerned with the secret prizes program that Tesla has set up. In addition to “amazing adventures,” top referrers will also have the opportunity to purchase a Tesla Founders series next generation roadster at a 10 percent discount.

California isn’t the only state where Tesla has run into problems with its program. In Virginia, a similar program that gifted $1,000 to the referrer was challenged and adjusted so that $2,000 would go to the buyer instead.

“If Tesla is compensating current owners $1,000 for selling a Model S to their friends, they are out of compliance,” Bruce Gould, executive director of the state’s Motor Vehicle Dealer Board, said. “What’s the difference between selling a vehicle and convincing someone to buy a vehicle? There has to be a line.”

The same logic seems to be in order for the secret level referral program as well. Tesla responded to the recent letter of complaint.

“This is just another example of car dealers trying to interfere with us and our customers,” the company said in a statement. “The regulations prohibit rogue car salespeople. Does anyone seriously think our customers are salespeople that the public needs to be protected from?”

For Tesla referrers looking to reach the next secret level, this can be seen as a speed bump toward that goal. As the DMV reviews the complaint, Tesla may have to rethink the structure of its referral program.