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The New York Times broke a story that major American retailer JC Penney had been using fake links to propel it to the top of virtually every product search return in Google.

The search engine giant promised swift action, with JC Penney falling in many search rankings shortly thereafter.

While I am happy to see Google take action, the question does beg - if the story wasn't exposed, would Google have done anything?

There are many companies out there offering to juice websites through fake links - and businesses must be supporting them. At what point does this practice become the norm?