Google had detected previous guidelines violations related to JCPenney.com on three occasions, most recently last November. Each time, steps were taken that reduced Penney’s search results
Especially in light of this...
A Penney's spokesperson denied that they had authorized those links - and they fired their search consulting firm.
Apparent JCP and Google had crossed paths before. I wonder what those "steps" that were taken earlier by Google were. I also wonder if the firm who placed these links for JCP was the same one that was involved in the previous efforts.
[OK, I had to turn on cookies and accept 18 from the NYT site before I could get past page 1.] .