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Not quite.
Any creature can two weapon fight with unarmed strikes.
If a creature has multiweapon fighting, then it can make an attack with all available unarmed strikes as a full-round action.
Exactly how many those are, is debatable.
If we look at the Monk, we see it noted "A monk's attacks may be with fist, elbows, knees, and feet.", and we see in the description of unarmed attacks as "punches, kicks, and head butts".
So, for this Ubue, he can attack with three Head butts, three punches, three elbows, three kicks, and three knees.
So, fifteen.
Awesome part, it only takes one casting of any spell to effect them all, as the unarmed strike is limb-agnostic, but only when it's beneficial.

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Indeed.
Of course, if you create a limb based limitation, then that can effect creatures with less than two limbs.
It is entirely possible for a limbless creature to two-weapon fight.
Also, there are attacks that are not limb based at all.
Perhaps it is old hat, but the recent rules errata on unarmed strikes and two weapon fighting is conundrum creator.