I think they addressed this when they changed upvote payout. Now the first to upvote it only get's 1% of the payout, and the other 99% goes to the author....after about 15 minutes, then the curator reward is split between Author and the upvote (times vary), then after 30 mins it's 100% for the upvote (if there is any payout left). This prevents bots from just upvoting, now it's a human vs. bots thing!!

Darn it, I was the first to vote on your article.....well lucky you. J/k, but at least you are getting paid now!