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But there are also combinations when it's on top AND on the right.
Maybe when they have too many advertisers for some keywords they use both and when they have fewer then MSN puts them on the right?
I have a client that must be paying lots of $$$ for PPC (law firm). I don't really know how much, I don't deal with advertising part. And all the listings from his sector show up on the right.
Then I also have a personal project and in that area bids are minimum. For those keywords MSN shows ads in both sections (top and right).