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"I bet they are the only publishers violating the guidelines" - should be "aren't"?
This author needs to build his case before jumping to the conclusion, "And now, I hesitate to recommend it to anyone for any use." This was one article, on one day. It was clearly a scam, but it was one article. And if the Google complaint form is more focused on the publisher maybe that is because most of the problems submitted are from publishers.

The author needs to submit the complaint and move on.

I agree, there was an "other" section on the complaint form for him to use.
This could be what we consider "cloaking" in the ad industry. Ads containing legitimate content are submitted, but when a user clicks it, a risk assessment is done based on the users information (ip/location/js enabled/saving cookies etc).

If it's determined that you're unlikely to be a crawler or a person affiliated with the host site (google employee in this case) you're served a "Blackhat" ad, which is generally worded much more aggressively and against the TOS. High risk users are redirected to "Whitehat" pages which follow the TOS and generally don't attempt to actually convert a user. These high risk users are considered dead clicks.

A few years ago this was an insanely profitable industry on Google Adsense, but they've cracked down a lot. The new major space for this type of advertising? Facebook.

Facebook cloaking is pretty huge right now. Even more so now that they've started cracking down hard on affiliate ads. Still, everyone knows that when you are cloaking it's just a matter of time before your account gets banned. FB is getting harder to cloak everyday. (Not that I do any advertising on FB, it's too stressful.)
Isn't this just a very sparse interstitial in front of the article placed by the publisher?
Well that's certainly one weird old technique from a malicious advertiser.