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At least the actual, genuine result is visible without scrolling. A few years Google were paying computer manufacturers to set a special version of Google with more prominent ads as their default search engine. The net result was that if you got a new computer and searched for Firefox using their default, Google-supplied search the genuine result was actually below the fold in some cases.

Can you back that up with a citation?

Not trivially, unfortunately - I didn't save the information at the time and don't seem to be able to find details because it's buried under articles about Google's newer changes to increase the number of ads and the (equally ad-heavy) redirection page for URL typos they were paying OEMs to bundle at one point.[1] Basically, there's too much discussion of other bad practices for me to Bing or Google this one. Sorry.

[1] See http://blog.opendns.com/2007/05/22/google-turns-the-page/

Interesting. Do you have any more information about that scheme?

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