There are valid uses. My hybrid photo-sharing/blogging service lets you send an email update with thumbnails inline, so you can tell family/friends about your latest doings without making them click a link out. http://ourdoings.com/
I suppose you could generalize this by saying HTML email is useful when you have images that are informational, not just decorative.
I suppose you could generalize this by saying HTML email is useful when you have images that are informational, not just decorative.