Would This Cloaking Be Detected?

noscript cloaking

[Miop]

Someone mentioned in another thread that H1 tags being made to appear smaller would amont to cloaking, so I have a quick question about sites 'cloaking' - a competitors site has a load of H1 tags and words in between <noscript> tags - would this be picked up as cloaking or would the spiders just see it as a correctly tagged page as the font=small element would be missing?

[DaveAtIFG]

From this forum's charter [webmasterworld.com],

Cloaking is delivering one version of a page to a search engine spider while serving users another version. The benefit is that your html code is hidden, giving you some measure of code and copyright protection.

As to information enclosed in <noscript> tags, last time I looked (a long time ago), it was ignored by most leading SEs.

[Miop]

Ignored as spam, or ignored altogether?

[DaveAtIFG]

Ignored altogether.

[vrtlw]

<nosript> is certainly indexed and is currently not penalized automatically by google