1. There is no way he the the only one or first one. Chances are that more than likely he was subscribing to some third party services which were offering this feature.
2. He probably took it too far to get noticed and get in limelight
There are plenty of ways to violate a TOS non-remuneratively or without using deception ("deception" is an element of the crime of fraud and has to be proved up in court; it's not simply what the TOS says it is). Those are civil matters, not crime.
The template you want to be working from: lying for money is fraud.
As in? If the LLC operates as a one man operation essentially, there isn't much ground for them to appear legitimate (but why not?). However a more thorough operation with an independent board, employees, senior staff, and now the company is liable not the individual?
It's an interesting discourse - what makes a company seemingly legitimate? AFAIC the whole purpose of an LLC is to shield individuals from liability. So why is it wrong to do that in one case, and not the other?
Oh wait - maybe it has got something to do with intent. An intent to commit fraud (in his case, like clicking on ads on one's own site). If that preceded the establishment of the company, then the whole company was a sham, never meant to operate as a successful legitimate business but only as a coverup. That is the most meaningful distinction I can think of.