Apparently JC Penney was doing a paid link scheme to make sure that search queries of the styles of clothes they offer would get preferred ranking by Google. Well it worked for them for a while, however Google found out and is now penalizing their websites.

Darcie Brossart with JC Penney's said they did not authorize this, and Google is saying they will take action until JC Penney's is able to remove the links. Their Black Hat SEO Company that JC Penney's was using has been terminated.

Remember it does not pay to do under handed SEO Techniques to get up in rankings, as you will get caught!