Not sure about that. I feel like someone who spams 100 takedown notices, and only 1 of them is legit, should be treated differently from someone who legitimately sent out 1000 takedown notices, and 900 were legit.
In the UK we have a thing called Northampton bulk court. This is an automated court which is used to issue fines and summonses locally. people can actually integrate with it with their billing systems.
I've had three summonses for things that weren't valid/legitimate. Each one of these costs me literally a day to sort out.
The cost of each of these "misses" costs someone time and money. They should be fined for each invalid claim.