How to Create Multiple Google Developer Accounts?

Hey guys

I lost my Google dev long ago and I want to make another one; possibly more than one.

Anybody know the best way and safest way to make these accounts now and to also keep them secure from not getting flagged?

What I know

1. Need a VCC that Google has not banned (20)
2. Use Virtual Server to access Account?

If anyone can fill me in that would be cool

Thank you

Anyone? :\\\

hey there

i was doing alot of app spamming a while ago and these is what i did

get a vps
get a vcc
make a new gmail with a virtual phone service
use vcc for google dev account

wait 1 day after creating gmail account
wait 3 days after creating dev account to upload apps


the trick works...but now they catch you by the code you're using its quite different nowadays