JC Penney engaging in black hat SEO techniques in which thousands of unrelated web sites in the retail industry were linking JCPenny.com. The process was done by linking very specific keywords in a manner that was cheating their way to the top of Google.
In order to foster results and return on investment for a Web site development project, there are several elements which require consideration. The 1990s did not require the sub-specialization needed for today’s successful Web sites. Does your website developer really understanding your business objectives? Does your website developer understand marketing? The disciplines needed for today's website have matured to a level beyond the average website developer. Does your website act as a business tool to generate revenue or is it merely a brochure?