But who wants to put in the effort to develop tracking for non-JS users? In reality, most will just ignore the few users that don't want to be tracked. Even ubl

But who wants to put in the effort to develop tracking for non-JS users? In reality, most will just ignore the few users that don't want to be tracked. Even ublock origin should be enough for most. However, IP is certainly used. I know of a few cases where IP is at least used as a filter. Most websites won't see that many users from one IP address.