Somewhere up higher in this thread, it was suggested that the misuse of Make for commercial work does not happen that much. (I don’t have time to re-read the entire thread to grab a quote.)
I’m am of the opinion that it happens way to much. Several times a week a poster actually admits misusing Make here in the forums. (Often they are not very good at English and likely do not understand the EULA even if they have read it.)