no, they are all valid transactions to users who just haven't been born yet
But you could just use OP_RETURN! Better: you could use OP_RETURN inside TapScript and just commit to the blockchain, instead of burning coins! There is no reason to burn anything, there is also no reason to bloat the chain. Another thing is that one commitment for the whole network would be cheaper than pushing every commitment for every user.
using OP_RETURN to store data in blockchains actually creates far more bloat then the method we are describing here.
the maximum amount of OP_RETURN data currently supported by the network per transaction is 80 bytes.... i think..

it has been awhile since i checked.
by using a sendmany transaction i can fit somewhere up to 3K 20 byte chunks into a single transaction.
around 60K per transaction. (very rough estimate) apertus.io's default bitcoin wallet settings currently cap the transaction size to 300 or 6K.. this is an adjustable setting. apertus.io is designed to work on 100's of other altcoins as well... not just bitcoin.
would you prefer i store a 60KB picture of my daughter's cat using 700 transactions or 1 transaction?

<3 #embii