This was the basis of a Sunday NYT profile of an online retailer whose verbal abuse of customers created such commotion that he actually moved up the Google rankings (here's my post). That's because Google apparently did not delineate between good commotion and bad. Anyway, Google is out with a post that says the loophole has been resolved.
Even though our initial analysis pointed to this being an edge case and not a widespread problem in our search results, we immediately convened a team that looked carefully at the issue. That team developed an initial algorithmic solution, implemented it, and the solution is already live. I am here to tell you that being bad is, and hopefully will always be, bad for business in Google's search results.
We can't say for sure that no one will ever find a loophole in our ranking algorithms in the future. We know that people will keep trying: attempts to game Google's ranking, like the ones mentioned in the article, go on 24 hours a day, every single day. That's why we cannot reveal the details of our solution--the underlying signals, data sources, and how we combined them to improve our rankings--beyond what we've already said. We can say with reasonable confidence that being bad to customers is bad for business on Google. And we will continue to work hard towards a better search.