Hello,
Unfortunately I am not in position to give legal advises, please check the
Terms and Conditions. Please make sure you only use your own developer token
though.
http://code.google.com/apis/adwords/docs/terms.html
As for part 2, we currently have no public interface for account creation.
It is possible to share number of pre-created accounts between your users
but make sure to keep track of billing on your side.
-Danial, AdWords API Team.
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Also find us on our blog and discussion group:
http://adwordsapi.blogspot.com
http://groups.google.com/group/adwords-api
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