After the NYtimes investigative report on JC Penny’s dirty search secreats, the question of white hat or black hat seo is being discussed a lot. There is also a middle line of grey hat seo, where the mix of White hat & black hat seo is used. Search engines have published a set of best practices confirming to which is like a white hat seo. Anything unethical & against the search engines guidelines is black hat. Search engines are refining the guidelines regularly, drawing a clear line between white & black hat. JC Penny has also fired its search firm over the methods the firm has used. Google also penalizes the sites found to be using the black hat methods.