It seems like he's just working the freesite and offering as many possible outs to a hairy sponsor as he can get. You, ATK, and then a mini-hub he's set up with his various freesites, sponsors, etc. I really wouldn't see a problem with that as...but I'm not a LL reviewer
However, I am a TGP reviewer and the question that pops up in my mind...is that hairy content he's using? When I see "hairy" galleries submitted to my tgp...it's hairy...I mean either an untrimmed bush, under arm hair, or both. The model he's used is clean under the arms and the beaver is neatly trimmed. If he were submitting the gallery to me and put it under the "hairy" niche I would change the category as that content doesn't seem hairy to me.