My guess would be that some major public CDN (Cloudflare etc) will let the attacker deploy their TLS-SNI challenge certs, and thus validate for other victim domains using the same CDN service.
EDIT: Main reasoning being that I can't think why it wouldn't work - apart from the TLS-SNI challenge certs somehow being considered invalid by the CDN provider and refusing to deploy them, but I find it hard to trust that happening with 100% certainty.