I think "very black hat" is pushing it a bit. That would be something like the worms and trojans people have used to take over accounts and spam everyone. But

I think "very black hat" is pushing it a bit. That would be something like the worms and trojans people have used to take over accounts and spam everyone. But paying people to push your page is definitely sketchy, especially since I'm sure there was no disclosure on the part of the pushers. I'd call that mesh hat.