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Even taking into consideration positioning I think that developing a bot that would figure out foreground/background colors for a particular element wouldn't be that difficult.
One or two days of coding for me--tops.
I recently noticed that some websites using the same CMS tool that I use insert a h1 tag in addition to the normal CSS tag. When I look at the Google cache (text cache) of their websites, I noticed the BIG font typical of h1 and sure enough there it was in the HTML.
When I examine my website in Google's text cache, all of the letters are the exact same size, regardless of the CSS style applied. I changed the code to include h1 (and defined h1 in the CSS description) just this past Saturday and applied it to my "headers" on the page. The page Google grabbed on Sunday shows the cache text headers now as h1.
To me (a newbie to SEO), I thought this change was essential because it meant that Google had not been understanding my CSS and didn't recognize Header text from the rest of the page's content.
Googlebot certainly does fetch CSS files. If you use a web page extension instead of .css (such as .asp or .php) for external CSS files you'll find them listed in Google's SERPs.
Still, hiding text could be subject of googles TOS, but Im sure there will always be ways of manipulating the path for googleBot to take (or not to take).