PTY DOS vulnerability?

[Fredrik Tolf]

Has someone considered PTYs as a possible attack vector for DOS 
attacks? Correct me if I'm wrong, but cannot someone just open 
all available PTYs on a console-less server and make everyone 
unable to log in?

I mean, what if eg. apache is hacked, and the first thing the 
attacker does is to tie up all PTYs, so that noone can log in to 
correct the situation while the attacker can go about his 
business? Then the only possible solution would be to reboot the 
server, which might very well not be desirable.

If you want proof of concept code, look at
http://www.dolda2000.cjb.net/~fredrik/ptmx.c
I successfully ran this on one of my servers which effectively 
disabled anyone from logging in via SSH.

Shouldn't PTYs be a per-user resource limit?

Someone must have thought of this before me, right? How am I 
wrong?

Fredrik Tolf