I think it depends on what your real definition of start-up is. Is it only businesses that can scale and create huge amounts of wealth? Or does it refer to anything someone starts with the intention of becoming profitable and supporting themselves? I can imagine that with enough time and hard work some of these apps thrown together can indeed produce returns, and might even give someone some financial success. Sure, they're not likely to be the next Google or YouTube or Amazon, but I don't see a problem with people cranking out code if they so choose.