plaintiff in Promatek, Dr. Banks used Standard Process trademarks in the
metatags of his website. However, today “modern search engines make little if
any use of metatags.” ... As more and more webmasters “manipulated their keyword
metatags to provide suboptimal keyword associations, search engines
progressively realized that keyword metatags were a poor indicator of relevancy.”
Accordingly, search engines today primarily use algorithms that rank a website
by the number of other sites that link or point to it."