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1script - 5:02 am on Aug 9, 2011 (gmt 0)
It certainly can - I've seen the examples. If the page loads and it's clear that the content is not the point, but rather the layout is pushing people toward the ads, then that page can get a negative Panda score.
Which actually brings another related question: would then not showing ads to googlebot (and other non-humans) for the sake of "true ad impression counts" be considered cloaking with the intent to "influence ranking" and cause all the bad consequences of cloaking?