I've had this exact experience many times myself and I'm also at a loss to explain how it happens unless Google is (unintentionally) facilitating it. An observa

I've had this exact experience many times myself and I'm also at a loss to explain how it happens unless Google is (unintentionally) facilitating it. An observation I can add is that the dummy site may not appear on my first search for "very unlikely phrase". But if I keep tweaking my Google search, a dummy site that has "very unlikely phrase" as its title soon appears in the results.