Sure, you can say "only accounts that haven't been used at all" (and then you have to define "used at all")...

The issue for me isn't that squatters can post a few token entries and get around activity restrictions. It's that activity requirements ignore activity that can't be quantified on the profile page.

For example, I had a few meat-space friends who signed up for LJ accounts not to post entries but for access to locked journals and communities. One of them didn't even post comments for the first two years, so their profile page read as if it was completely unused.