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I understand the theory but I disagree. When you use your H tags properly it doesn't necessarily make a difference where they are located. H1 tags are usually the title, so it is better to have them higher on the page, however it doesn't negatively effect you if they are closer to the bottom of the page. My h2 and h3 tags are actually above my h1 tags and I have not seen any negative effects from this. The important part of these tags is the keyword use and whether or not they are used in order of importance, h1 most relevant to page, h2 is like a subtitle and so on.