As the Internet becomes increasingly accessible, businesses are focusing more attention on their online presences and regularly hire outside firms to optimize their websites in order to rank higher on Google and gain search engine traffic. A business not familiar with search engines, however, is less equipped to ensure that its search engine optimization firm is using reputable techniques. Not using reputable techniques can result in a search engine penalty, which can range from the webpage’s rankings being lowered to the website being removed entirely from the search engine. This Note explores the possible causes of action a business has against a search engine optimization firm that uses nonreputable techniques without the client’s consent when it leads to penalty. This Note also proposes reforms that can better protect such businesses.