I am not clear. Can you describe it more. BTW we have enabled SMTP AUTH too. I think there should be a way of limiting the number on Mail Server itself.
there are some ways - google for "rate limiting qmail"
1. he could bypass your qmail and install smtp perl libraries that send out directly
2. he could set up scripts on your server to connect to various proxy servers and send spam through those proxies
etc etc etc.
If you have to ask, I am afraid you are in the wrong line of work, and will be fighting what is essentially a losing battle. Quite a lot of spammers are technically clued these days, or at least have access to scripts that are not easy to detect by just rate limiting your qmail and enabling auth (though these are essential too)
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