There is a destructive trend across the Blackhat world right now which is going to cause a lot of problems for people. Mixed signals on the causes of penalized sites and case studies on sites using Blackhat techniques which seemingly didn’t get hit are challenging what we’ve learned from Penguin 2.1 so far.
Don’t fall into the trap, most of the sites that used spam to rank and seemingly passed by Penguin 2.1 were very young sites. I have young sites which also didn’t get hit by Penguin but that doesn’t mean the link technique worked, it means Penguin crawled the web before I made the site or a similar scenario.
Make no mistake, the next Penguin will catch the site.
Now, for churn and burn this isn’t a problem, in fact it is a blessing in disguise as the competition is wiped out and we are here to rank and bank but what i’m trying to say is that you should use your common sense when people talk about beating Penguin. If someone is claiming to have beaten Penguin using spam, have a thorough check of their site, it is probabaly too good to be true. If it is less than 3 months old then that is why it didn’t get hit.