Cloaking is one of the negative ways that webmasters use by giving different contents to search engines and human beings. By manipulating search rankings through optimised content which can be seen by the search engines and dangling less related or unrelated content to visitors, it is the intended purpose. Most examples include showing keyword-stuffed pages to search engines while showing user-friendly pages to users. The practice of cloaking is against the law of the search engines, thus risk high penalties, from being de-indexed. Ethical SEO, on the other hand, provides consistent quality content to both search engines and end users.