That's why, according to Optimization-Nation, you can do a keyword search, click on a good result and end up on a page with no content related to the keyword.
The Google team talk a lot about what they do to get around the blocks malware writers put up and four methods of malware search they use so they can compare results that will highlight as malicious sites whose results from the different approaches don't match.
They don't say much about any long-term or highly successful countermeasure to IP cloaking, which makes me think – along with the impressive variety of really well informedpeople who are really enthusiastic about cloaking and do not have the best interests of the rest of us in mind – we're going to see a lot more trouble with cloaked sites in the future than we have until now.
If there's one thing malware distributors have gotten good at, it's hitting the users where the malware scanners ain't. From a malware perspective, cloaking seems like a perfect answer.