rocknbil - 4:25 pm on Oct 25, 2011 (gmt 0)
In all fairness - although I fought it tooth and nail - it may just be the design. I just completed a project with "tabs" on all the pages and the tabs appeared right under the header stuff.
No visible h1. <gasp>
So when the SEO people approached the project, they're thinking "what the heck, what are you thinking?" We put some in with exactly that approach . . . also sticking poorly in my craw.
You've opened a good question though. When, for whatever reason, an h1 is set to display:none, is this considered "hidden content" by the S.E.'s, and does it inflict their wrath, especially if the h1 in question is both relevant and non-stuffed?
Alternatively, an image-based h1, which I doubt is the same environment because the h1 content is similar or identical to the graphic content.