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So, unless you are doing very dodgy stuff :) I'd say the risk is minimal...as long as the punter gets what they were after, even if you get reported, odds are slim to none you'll get 'bumped off'.
However, also depends on the competition for any given phrase...no search engine can risk upsetting the folks that pay the big $$$.
"The sites I've seen busted en masse for 'cloaking' are usually busted for 'mass produced auto generated pages' and not for 'just cloaking'."
I'm not that experienced with cloaking, so I'm not quite sure what you mean by "mass produced auto generated pages" and how it relates to cloaking - care to explain?