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First of all :
Some example of gray hat is "duplicate content" - NOT true. Actually duplicate content is not even part of the process you call SEO.
There is either white hat or black hat. You can either comply with the rules or you don't. Grey hat is just a reason for some to claim they are not blackhat, when actually they break the rules.
Black hat is made by programmers who really know what they are doing, we are not talking here about text outside the screen reader to stuff keywords there ( and YES, more keywords is better, you can go with density up to 50% and you will be surprised by the results ) or use of hot targets.
When I say blackhat I say something about the real thing, people that get really high for creating networks and tricking the SE.
IMHO there is no such thing as grey hat.
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