I disagree slightly in that vast majority of tech startups don't have any money. They need people they don't have to pay. What better way than to give everyone who walks by a flyer? Comparatively, dev shops need to be able to get another customer, so they need to produce something that does at least work regardless of whether or not it scales. They need people who can build something right out of the gate or the clients don't pay the invoice. They don't have the time to spend training someone.