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You also have to remember that you don't always write a program like a virus with malicious intents. Sometimes you want to do something just to prove to yourself that you can. (I'm not saying that's what this guy did).
I think that used to be true. I can remember back to the days when viruses were boot sector or file infectors, and there was a period of time when the "competition" seemed to be who could write the smallest virus. These HAD to be non-malicious, as there just wasn't room for a payload.