Inevitable so long as it's so low risk
There is a commenter above questioning how effective this would really be.
Perhaps not overly effective but such services are actually pretty damned cheap. Mostly they're farmed out to uni students. The fact is that given how cheap the service is, the potential benefits make it worth it. Even more so if the risk of being discovered is so paltry.
It might be a low-percentage play but it has a chance to pay off big if media outlets start reporting on the apparent customer dissatisfaction. So many 'normal' media outlets scrape news items from blogs and social media so all it takes is a few such sites to run some stories about people being disappointed with the handset and it goes from there. It's happened before.
This is a perfect situation to apply punative damages. Such rulings are there to offer a real deterrent so that the companies can't just consider these fines a business cost, which is what happened.
These unethical business practices work because the potential benefits far outweigh the potential penalties so there's not possibility of a $340,000 fine deterring Samsung or others in the future.