The old days it used to be doing stuff like adding keywords to a page... black text on a black ground, link4U link exchange programs... Things have come a long way (that doesn't work anymore) and with the combination of databases and programmers, the gray is much wider... Building out hundreds of thousands or millions of crafted pages can now be light gray hat... and the black hat stuff today is server side cloaking (serving up pages to search engines that are different than what a person sees), being able to launch a few thousand domains in a matter of a few hours, blog and article scrapers and other cool hacks that search engines don't like.
So I've been told.
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