Gmail fights image spam with OCR
google.com
google.com
But there could be a reverse CAPTCHA where spammers send images with text that OCR engines can't recognize.
Any public breakthrough in OCR to solve the spam-CAPTCHA would actually hurt efforts to stop spammers who could beat CAPTCHAs to signup for more accounts. How ironic :)
Also, real OCR is too expensive to do at the volumes of mail being sent today. Gmail is likely using an OCR-esque technique that has lower precision but is much faster to process a given image.