The New York Times recently noticed something odd when performing Google searches on terms as diverse as bedding, skinny jeans, area rugs and grommet-top curtains. "You could imagine a dozen contenders for each of these searches," writes David Segal. "But in the last several months, one name turned up, with uncanny regularity, in the No. 1 spot for each and every term: JCPenney." The retailer's ranking even bested manufacturer Samsonite.com in Google searches for Samsonite carry-on luggage.

The newspaper asked Doug Pierce of Blue Fountain Media to investigate, and he discovered the strikingly unsubtle use of "black hat" optimization—including an array of phony sites that appeared to exist for the sole purpose of linking to the store's website.

"There are links to JCPenney.com's dresses page on sites about diseases, cameras, cars, dogs, aluminum sheets, travel, snoring, diamond drills, bathroom tiles, hotel furniture, online games, commodities, fishing, Adobe Flash, glass shower doors, jokes and dentists—and the list goes on," notes Segal.

Though not illegal, black-hat tactics are strictly verboten in the Google rulebook. "The company draws a pretty thick line between techniques it considers deceptive and 'white hat' approaches, which are offered by hundreds of consulting firms and are legitimate ways to increase a site's visibility," Segal explains.

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