That won't happen, because spam has no value
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But it has happened and still does. we saw crazy crap hitting the mempools already.
You aren’t thinking from an attacker point of view. If money isn’t a problem and their goal is to throttle the network throughput they would make it expensive and difficult to transact.
They can already do that by sending legitimate transactions back and forth between wallets
It never lasts very long though. People get tired of burning money eventually