The Gmail requirement is actually slightly different: the header must be present and unique. Gmail only keeps one copy of a message per user and message ID. Combined with a mail source that uses predictable message IDs (such as Github), you can abuse this to suppress delivery of certain messages to Gmail users.
realusername|17 days ago
ZoneZealot|17 days ago
Comments on issues use the format <[OrgName]/[RepoName]/issues/[IssueNumber]/[CommentID]@github.com>
A mitigation to this would be to take the combination of message ID and the sending domain and use that as the unique value, because message ID is not guaranteed to actually contain a domain label that's owned by the sender.
For example SendGrid's message IDs are <[RandomValue]@geopod-ismtpd-[Integer]>.
fweimer|17 days ago