If I only had a dollar for every place one of those stupid "angelfire" sites has edged me out! The industry for my site in general lends itself particularly well to free sites, so I find them abundantly in the top 10 for most of my KWs. If the SEs don't penalize, they certainly should. Just on the basis of annoyance alone. It doesn't seem to matter how crowded their site is with ads or that they have those damn popups!