The media does offer perverse incentives to people looking to make a buck through infamy. I'm sure RapeLay wasn't actively looking to cause a stir and just happened to be "that game" people noticed at random but this kind of thing happens every so often. Not too long ago there was some media reaction to a game depicting the Kennedy assassination. I'm sure that negative media attention helped the product. That trend might serve to inspire people to actively pursue media attention.
I'm sure if we put our heads together to come up with a game that was as offensive as it could be by being grotesquely racist and allowing the player to engage in sadistic violence and sexual deviance, we'd get on CNN too. I personally wouldn't want my name associated with a product like that but for people who don't mind then the infamy angle can be a profitable one, more than obscurity at least.