Blackhat SEO attempts to improve rankings in ways that are either unethical, disapproved of by the search engines, or involve deception. One blackhat technique uses text that is hidden, either as text colored similar to the background, in an invisible div, or positioned off screen.

I mean when we look at the comparison to the right, they are pretty much doing the same things. The difference being that one gets paid ludicrous amounts of money and the other gets shut down.