Black hat SEO involves techniques such as paying to post links to a website on link farms, stuffing the metadata with nonrelated keywords, and using text that is invisible to readers to attract search engines. These and many other black hat SEO tactics may boost traffic, but search engines frown on the use of such measures. Search engines may punish sites that employ these methods by reducing their page rank or delisting them from search results.
Website owners recognized the value of a high ranking and visibility in search engine results, creating an opportunity for both white hat and black hat SEO practitioners. According to industry analyst Danny Sullivan, the phrase "search engine optimization" probably came into use in 1997. Sullivan credits Bruce Clay as one of the first people to popularize the term. On May 2, 2007, Jason Gambert attempted to trademark the term SEO by convincing the Trademark Office in Arizona that SEO is a "process" involving manipulation of keywords and not a "marketing service."