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It is quite possible, the pages with hidden text, would be ranking just as well without it. let's face it, just because a page uses underhanded methods does not mean it is not the most relavent page to return.
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I agree. Almost every page I have seen with hidden text that ranks well, is probably ranking well for reasons other than the hidden text. It would make sense for Google just to ignore it rather than penalise for it (as the site may have valuable content).
BTW - there is not a lot of difference between the keyword spamming that is hidden at the bottom of the page vs the keyword spamming at the bottom of the page that is not hidden (eg the site mentioned above :-)
CBP