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.
ICO made more than $22 billion only in the US in 2018 and a big number of ICO had been scams which mean that people lost their money for a white paper which is simply pathetic. ICO is no longer the point of attraction for the potential investors who are looking from profits by investing in early tokens. They have started targeting IEOs. The only option open to ICO is to promote but I fear if promotion would do any good.