Yes I think this is unethical. You don't have to spend 9M$ for promotion. That is not practical. In my own opinion we don't have any expensive promotions because the best way to market ICO and other crypto is the success of the investors coming from crypto or ICO. When it happen we don't have to pay any advertisement.
Of course, if you take into account advertising that is paid for in real and big business, then these are really hundreds of millions of dollars. But if you take into account the Bounty company, through which hunters advertise certain Eco companies, the prices are almost ridiculous. It is a pity that recently the ico market of companies has been greatly deceiving Not only the investor, but also the Bounty Hunters. I think if IEO succeeds in taking root in the cryptocurrency market, then the company's ico market may be in danger of disappearing.