If they were spamming these yea they
could be in violation of
SEC 5 (b) (2) , which also applies to the use of generated accounts to transmit email or be used as a from address etc.
Quote:
(2) AUTOMATED CREATION OF MULTIPLE ELECTRONIC MAIL ACCOUNTS- It is unlawful for any person to use scripts or other automated means to register for multiple electronic mail accounts or online user accounts from which to transmit to a protected computer, or enable another person to transmit to a protected computer, a commercial electronic mail message that is unlawful under subsection (a).
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