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The penalty mentioned in the article wasn't even a link based penalty... The Moz spam score looks at the quality of links pointing to a domain and has nothing to do with spam content on pages - so that score is irrelevant here. Having the penalty removed could have been as easy as clicking the 'Request a review' button so Google would check to see that the domain no longer contains any auto-generated spam. I would also have to ask why the person even wanted these domains? They are clearly up to some black hat SEO tactics and should probably stop complaining about Google penalties...