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I would assume that it has something to do with the amount of resource consumption allotted per dev account. The more domains you have, more than likely you will be consuming more resources with the developer tools.
This is just my view on the whole matter but from a dev perspective (not including dedicated servers) wouldn't you want to focus your developmental skills on 1 or a couple domains. And not spread them over several domains.
It just seems to make more sense when you are developing something to not spread out things over multiple domains. Or atleast, no more than 3.
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