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."[67][68]
Search engine optimization consultants expanded their offerings to help businesses learn about and use the advertising opportunities offered by search engines, and new agencies focusing primarily upon marketing and advertising through search engines emerged. The term "search engine marketing" was popularized by Danny Sullivan in 2001[12] to cover the spectrum of activities involved in performing SEO, managing paid listings at the search engines, submitting sites to directories, and developing online marketing strategies for businesses, organizations, and individuals.

Remember when you used to rely solely on search engines for traffic? Remember when you worked on SEO and lived and died by your placement in Google? Were you #1? Assured success. Well, okay, maybe not assured. Success only came if the keywords were relevant to your site users, but it was the only real roadmap to generating site traffic and revenue.
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