Distributed bot and scraper networks. Thousands of IPs geographically dispersed throughout the world. There is only so much you can do with rate limiting.
I go to LinkedIn without being logged in and nearly always get a login gate instead of the profile.
They were ordered to unblock hiQ specifically, they were not ordered to open up content to scrapers generally.
They can still throttle high volume traffic and put up captchas. I think the only specific thing the court ordered was for them to unblock hiQ IP ranges.