Moz's campaign tracker throws a warning once you hit 100 links, and I think that's a pretty solid estimate.
Posts made by Navolutions
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RE: How Many Internal Links are Too Many?
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RE: Is this a clear sign that one of our competitors is doing some serious black-hat SEO?
Why not just open up their link data (on the Moz toolbar) and take a look at where they're getting these links from?