How about this heuristic:

If the note is longer than, let's say, 30 characters and it repeats 5 times or more within 7 days, it's considered spam.

This wouldn't stop all spam but at least be a step on the way, while allowing plebs to respond with the same message if short.

That said, there might be legitimate notes that are inadvertently flagged as spam. Also the function would need to calculate a percentage similarity between notes.

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