The NYtimes published an article about unethical methods of SEO (search engine optimization) and basically called out JCPenny who used such methods.
First off, as an expert in the web marketing industry I have to say: most sites use such methods to increase their visibility. This is nothing unusual, really.
The fact NYTimes decided to call out JCPenny and practically force Google to react seems a bit odd to me. They could have chosen almost any other website on the internet and show it does correlate with Google's webmaster guidance, but they chose JCPenny and even monitored how Google will harm them as a response to the article that was submitted to the head of the spam team Matt Cutts.
My bet is that they hold a secret interest to do so.The big retail stores that compete with JCPenny have probably earned millions just in the last months since JC dropped in ranks. Like always - in business, no one does anyone favors for free.