We are talking about phishing here. Don't you think they have access to a lot of recently-phished credit cards they could use to buy the forms? They would probably choose for a free competitor most likely since that is easier to automate and you don't need the hassle to try out the credit cards. I'm pretty sure web hosting companies already get a lot of phishers paying for an account with a phished credit card, though.

By the way, the scammers on dating sites use a lot of paid accounts (and pay for them themselves most likely) considering they get a lot more money out of it and a paid account seems more legitimate. Just to say that making something paid does not necessarily remove all the abuse.

Methods of abuse never stop evolving so long as there's a free product available to attempt to hijack. The problem won't stop being persistent, and the government is only going to get more frequent in their take-downs. Switching from innocent until proven guilty, to guilty until lucky if you can even defend yourself, will eventually make it very dangerous to open yourself up via free services.

Worse, if the government keeps lowering the bar on qualification for shutdown, the margin for mistake will be so small that the best effort possible won't be good enough. There will be mistakes, fraud will slip through, and boom you're toast.

If the Feds keep going in this direction, at some point the risk of a free system will not outweigh the benefit. Before 2012 is over, there will be enough of these examples to start scaring the hell out of the average web service - if we're not there already.

Government enforcement of policies like this rely on scaring large numbers of operators through a small number of intense persecutions. It works unfortunately.