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A perfect example of a conspiracy theory.They are NOT loopholes.
The rules are purposely designed to allow such things.
But I don't suppose anyone will be accusing you anytime soon.conspiracy theory
noun
- a belief that some covert but influential organization is responsible for an unexplained event.
If they're not loopholes, and designed that way, it must have been done by a covert, influential organisation. And you offer no explanation for those loopholes.
Therefore your theory has all the hallmarks of a conspiracy theory.