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volatilegx - 6:50 pm on Aug 28, 2007 (gmt 0)
The fact is, most people who are using "naughty" cloaking techniques don't pay enough attention to off-page factors such as incoming links. What used to work like a charm in the past (on-page optimization) now plays second fiddle to getting one-way, on-topic links from trusted sites.
I think a major reason cloaked sites (for naughty reasons, of course) don't do as well as they have in the past has to do with the whole paradigm of SEO changing from on-page factors to off-page factors.