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To be perfectly honest, if a person knows what a title and an H1 are, there is gaming going on, it's all a matter of degree.Using appropriate titles and H1s can hardly be gaming the system if people are just following the advice given by Google.
Make sure that your <title> elements and ALT attributes are descriptive and accurate.
<h1>Brandon's Baseball Cards</h1>
(1) On a page containing a news story, we might put the name of our site into an <h1> tag and the topic of the story into an <h2> tag.
[edited by: aakk9999 at 9:28 am (utc) on Sep 18, 2013]
I would say instead that Google believes their title is a better fit for that query.
and instead focus on the content itself
If the h1 doesn't count as content, what does?