They are quite hard limiting the step 2. Seeing that even some bigger profile titles don't get enough keys to allow them be on quite well selling bundles like Humble Choice. At least not before they have generated enough organic sales.

Also gems have absolutely horrible conversion ratio. I think lowest I can find in my inventory is 6 gems per copy of game. You can sell gems for 0.30€ per 1000... So 167 copies. And accounts...

Not to forget that it cost 100 dollars I think to release game on Steam...