I interpret that the opposite way: if a huge spam campaign can be run by a guy in his bedroom, there’s no way that larger spam operators can be effectively killed by legal action. They’ll just employ different guys in different bedrooms. The same thing is true with phone phishing scams—they’re not individually hard to eradicate, but the combination of lucrativeness and rapid-rebootability means that legal crackdowns in the past have not been effective at scaring the rest out of business.