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With Penguin, it wasn't the quantity of links that improved a site's rankings but the quality. Since then, Google's web spam team has attempted to prevent the manipulation of their search results through link building. Major brands including J.C. Penney, BMW, Forbes, Overstock.com, and many others have received severe penalties to their search rankings for employing spammy and non-user friendly link building tactics.
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In October 5, 2014 Google launched a new algorithm update Penguin 3.0 to penalize those sites who use black hat link building tactics to build unnatural links to manipulate search engines. The update affected 0.3% English Language queries all over the world.

Black hat SEO could also be referred to as Spamdexing, which utilizes other black SEO strategies and link building tactics. Some black hat link building strategies include getting unqualified links from and participating in Link farm, link schemes and Doorway page. Black Hat SEO could also refer to "negative SEO," the practice of deliberately harming another website's performance.

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