Yes, I mean cold sales emails – marketers reaching out to CEOs or other decision makers, selling them staff augmentation services, growth hacking, marketing support, lead generation, design services, etc. They'd claim legitimate interest by "personalizing" the email and claiming that it is relevant for you in a business sense. (Anyway, I don't think that these are fully compliant with GDPR either, because most often, they will have scraped your email address from somewhere, and do not provide a way to unsubscribe.)