Lots of discussion of this elsewhere. It looks like some people who don't tether (but use a lot of bandwidth) are also getting the message, leading people to believe to that AT&T is looking solely at bandwidth usage. http://modmyi.com/forums/iphone-news/755094-t-cracking-down-... I use TetherMe ($2 in the cydia store, instead of $10 for mywi, enables native tethering), and I haven't gotten this message.
I certainly wouldn't be surprised if that was the case that they're just going after high bandwidth users and not doing packet inspection (yet). I occasionally swap my iPhone 4 SIM to a Nexus One and use the built-in wifi tethering feature, and haven't heard from AT&T about it. On the other hand I only have used maybe 2GB of tethered data over the last year and in general run up no more than 800MB-1GB of mobile data…
I use the Tethering on my Nexus One (Tmobile) from time to time, but I don't abuse it. I use it as an emergency backup internet access for cases like if the wifi at the hotel isn't working, etc. IMHO, that's reasonable and my usage when tethered probably isn't much more than when I run things like Pandora or Youtube on my phone.
If I were using 10+G/month, then I'd expect to have to pay for a higher priced "tethering included" plan.