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While rich snippets are generated algorithmically, we do reserve the right to take manual action (e.g., disable rich snippets for a specific site) in cases where we see abuse, deception, or other actions that hurt the search experience for our users. In particular, you should avoid:
Marking up content that is in no way visible to users.
Marking up irrelevant or misleading content, such as fake reviews or content unrelated to the focus of a page.
These quality guidelines cover the most common forms of deceptive or manipulative rich snippet behavior, but Google may respond negatively to other misleading practices not listed here. It's not safe to assume that Google approves of a specific deceptive technique just because it isn't included on this page. We strongly advise that webmasters focus on providing a great user experience rather than on looking for loopholes.
If rich snippets are not appearing for your pages in Google’s search results, check that you’ve done each of the following things:
Implemented markup in accordance with the above guidelines
Successfully tested using the structured data testing tool (http://www.google.com/webmasters/tools/richsnippets)
Reviewed our troubleshooting guide (https://support.google.com/webmasters/answer/answer.py?answer=1093493)
WOW, apparently everything is seen as manipulative by Google these days.
If the content isn't visible, they should just disregard it whether it's marked up or not -- If the ratings are fake what difference would it make if they're marked up or not, especially since Google's pretty good at detecting what things are without the markup, and how on earth do they know if the ratings are fake or not?
Because deterrents discourage bad behavior