ArteLight.de is a German online shop for lamps. At the moment, their PageRank 6 homepage is ranking 1 in Google.de for both 'Lampen' and 'Leuchten' , the German words for lamps. Now take a look at the counter code and check if you notice anything unusual (user ID removed, colorized): <!-- Logstats Counter Code --> <script language="JavaScript" type="text/javascript" src="http://www.logstats.de/pphlogger.js.php?id=..."> </script> <noscript> <img src="http://www.logstats.de/pphlogger.php?id=..."> <a href="http://www.artelight.de">Leuchten</a> </noscript> <!-- Logstats Counter Code --> Code (markup): LogStats (a service with 9,531 members, according to owner company Nolte Internet from Herford) is a little more than just a visitor counter – it's also a convenient way to trick sites into pimping ArteLight's lamps through a backlink contained in the noscript part of the counter code. Of course, the link is not completely hidden: it will be painfully visible to every webmaster taking the time to read through the counter code. However, the link will not show on the rendered page with typical browser settings, and users also aren’t visibly warned of the fact they’re part of a link building campaign for designer lamps. And when you sign up for LogStats.de, the terms of service emphasize that you are not allowed to include the counter in 'sites that support SPAMMING.'
I've seen another guy do a counter script with a link, not even a javascript, just an anchor around the image, and the image alt tag as his keywords. In other places he uses other methods like the one you mention above. He has shot to the top position for an extremely completive big money keyword. I'm sure google will catch up with this, but he's probably making $20,000/month or more until they do.