This is an FR2 (phenolic paper) board. I remember reading somewhere that for high volume, cheap production, FR2 is not drilled, but punched. You would need a special tool for every PCB layout with all the holes punches in it. I figure it is maybe cheaper to combine several board layouts into one punching tool (same hole pattern, different copper layout). That would keep the tooling costs lower, but would result in unnecessary holes in every board.