robdwoods - 8:10 pm on Mar 26, 2013 (gmt 0)
I have actually seen this in a SERP recently for a "lead gen" type of term. When doing a competitive analysis I could find no clear reason a new, thin site with few obvious links was ranking in the top 4 for a highly competitive term. I assumed it was an abberation or heavy link buying that the link research tools haven't caught up to yet and which Google hasn't caught up to and burned.
Churn and burn still works, just not for as long on a given domain as it used to.