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By the mere mention of a phrase you establish a 'relationship' to that phrase - at least this is how an engine could/would see it.
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I do not agree. None of the patents I've bothered to read based any sort of relevancy on mere mentions of the word.
Most patents dealing with relevancy establish relevancy by either re-ranking the top X number of results for a keyword by analyzing the interlinking of those sites, or by establishing neighborhoods and and analyzing interlinking there.
If a mere mention of a word established relevancy it would be very, very impractical.
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And, combined with the things that we know the search engines have a particular liking for eg title,link text,TRUST etc is what provides an engine with its form of relevancy.
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Which isn't very relevant, and that is my point.