Add to that that people are learning to either turn their Bluetooth off, or at least up the security settings, and it becomes an even less attractive spamming option.
“An engineer explained to us that hundreds of ear impressions were gathered in the name of research, and while each one obviously boasted its own unique shape and size, one single characteristic remained uniform across the board: the entrance into the ear canal is not a perfect circle, it's an oval.”
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How would you spam via bluetooth anyway since you'd not only have to be in range but surely you also have to be paired with the other device?
Add to that that people are learning to either turn their Bluetooth off, or at least up the security settings, and it becomes an even less attractive spamming option.