I agree, in practice I see this occasionally on gigantic GitHub pull requests with 1000+ files, or very clunky Atlassian/Confluence pages. I'd say both sides need to work on their resource management!
(On that note, many complaints about Safari I hear from developers fall on my ears as "I don't care about web compatibility!" as it has never NOT been the case on the web that you need to care about feature support and resource management.)