Until people wake up and stop paying for these services they will always be working to try and bypass any system Bungie puts in place. You can see why as there are too many D2 players who pay not just once or twice but regularly making it very profitable.
So they..
Make multiple accounts every day as the old ones are quickly banned. Even buying new copies of Lightfall every time.
Long drawn out legal action by Bungie. But I guess that these people just shut down and then restarted a "backup" company.
So what else can Bungie do.
English
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They could simply implement a filter for messages, obviously. It's pretty common among most platforms. Messages containing URLs, common soliciting phrases, etc would flag the message and account.
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They'd still try to find a way. Even if it meant sending one letter at a time.