That would be a legitimate way of gaming that. 

I've been wanting to kind of figure out a way of looking at npub behavior in general as a spam filter. So for instance, if you created all 10 of those accounts at the same time and they're only replies to where to each other Within a short amount of time of their creation, that could potentially be spammy behavior and could be blocked. 

spam filtering really just is a game of whack-a-mole. There's always some way to game a spam filter.