Since heading tags typically make text contained in them larger than normal text on the page, this is a visual cue to users that this text is important and could help them understand something about the type of content underneath the heading text. Multiple heading sizes used in order create a hierarchical structure for your content, making it easier for users to navigate through your document.
On October 17, 2002, SearchKing filed suit in the United States District Court, Western District of Oklahoma, against the search engine Google. SearchKing's claim was that Google's tactics to prevent spamdexing constituted a tortious interference with contractual relations. On May 27, 2003, the court granted Google's motion to dismiss the complaint because SearchKing "failed to state a claim upon which relief may be granted."
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."