12,000 nintendo club points worth of games is more than a lot. I think somehow broke it down to 200 or so games in whatever amount of time that points don't expire. Now multiply that by the amount of surveys you can do for each game, and finally multiply that by the amount of accounts he has. It would take an insane amount of time to do all those this, and for what? Some free downloadable games and a keychain? He could order dozens of any physical or digital reward they offer. It's more than he, his family, and his friends could ever want. So why is he doing it? The guy is either running a nintendo club points racket, or is a hoarder.
It doesn't matter if he's within the TOS it is completely against the spirit of club nintendo.