I think ratelimit would not help for disposable npubs - I mean ones that are generated for single event. If network is flooded with unique npubs ratelimiting is not really useful

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Well it depends. If you’re running the public relay that is being spammed, you can see what IP(s), ASNs, user agents, etc the spammer is using and rate limit on the network side.

If you’re an aggregator like filter.nostr.wine that doesn’t have that network view, then it’s MUCH more challenging. You need to focus more on the content/pattern of the messages and reputation of pubkey posting them.