The glib answer here is that there's really no such thing as the 2nd law when you're talking about a small number of individual fundamental particles. The statement "entropy never decreases" is actually a purely statistical claim, and it only rises to its usual level of essentially unbreakable validity when you're dealing with macroscopic numbers of particles (the number 10^23 gets thrown around a lot, though it becomes an awfully compelling "law" even with just a few hundred particles in the mix).
But as for your actual example, it's important to distinguish between virtual pair production and longer-lived pair production. A single photon can momentarily "decay" into an e-/e+ pair which then annihilates back into a photon, and in fact quantum field theory tells us that this sort of process is an intrinsic part of how photons travel through space. (Similar things happen for all other particles as well.) But conservation of energy and momentum during this process leads to weird effects like violations of the usual mass/energy/momentum relation of relativity, which is essentially why we call the e-/e+ "virtual" particles (or "off-shell"[1]).
For a "real" annihilation between an electron and a positron, you'll always wind up with two photons in the final state (necessary to conserve momentum and energy). By the same token, to produce an e-/e+ pair you'd need two photons, not just one, and those photons would need to have enough energy to provide the mass of both particles and enough kinetic energy to satisfy momentum conservation. I wouldn't invoke the 2nd law here (as I said above), but the point you're making is still valid: because so much of the e-/e+ energy is "used up" in their mass, there is less "phase space" available (fewer possible momentum states) in that configuration than as two photons, so the probability of winding up in that state is correspondingly lower. (Also, an electron and positron are electrically attracted to each other and will naturally tend to meet up to annihilate, but two photons have no such tendency.)
I'm not sure that any of that was interesting or useful, but there you go.
[1] https://en.wikipedia.org/wiki/On_shell_and_off_shell