I move the question!
Yikes....This was a very easy question and there was a quick and accurate initial response. Maybe I should post the question on the Maine Trial Lawyers site where trivia like this is debated daily!
And who cares if some don't care for this type of cache. While I have my favorites, I can honestly say I like them all and being critical of any particular type of cache is likely to create negativity in the caching community. My "pet peeve" is when an opinion is expressed that suggests a type of cache, the way one caches, why you cache, etc. is "better" or more "pure" then the way another cacher might do it. It's a GAME, and we all do it the way we like to do it.
Some of the responses to this simple inquiry should have been the subject of a different thread. How about one that is called "Pet Peeve caches?" Or "Caches I don't care for?" Or "How we used to cache in the good old days?"
Sometimes the road less traveled is less traveled for a reason.