A real test, I think, would take some time and effort to conduct.
I don't think it's enough to put up two pages to test navigation placement, for example, because it is the
consistency of navigation that helps a search engine differentiate between links that are content and links that are navigation. Give me six web pages using the same template and I can write a program in thirty minutes that will separate [url=http://searchengineland.com/070531-115312.php]Real[i][/i] Content[/url] from systemic elements like header, footer, and navigation. Give me only two pages, using two different templates, however, and my program would be lost.
I believe the placement of words within the content is important in determining relevancy for the same reason your ninth grade English teacher taught you to write a topic sentence for each of your papers. Good writers are going to do that any way. I also believe, however, that today's search engines are VERY good at paring content from supporting structure. Just like your teacher, the engines generally
know where to look for that topic sentence.
We all know you can put 10K of JavaScript at the top of a document and still rank well. The engines will ignore it. Similarly, I believe they will ignore a dozen table tags and the 2K of spacer images used to manage those tags when all that supporting code precedes the content. They have something like eight years worth of documents in their database that have been following pretty much that exact pattern, and programmers are darn good with patterns. I've seen evidence that points both ways, but I'm nonetheless convinced that standardized navigation, much like script and styles and table tags, will be parsed and considered quite apart from [url=http://searchengineland.com/070531-115312.php]Real[i][/i] Content[/url]. Today's algorithms, heavily influenced by link structure, almost demand it. Such being the case, it won't matter if your navigation precedes or follows the content, as long as it remains apart from the content.
It's going to take a lot more empirical evidence than simply two web pages to prove anything useful, though. Heck, we already know one has to rank higher than the other even if both are identically relevant, so the first test is just like flipping a coin to see if it comes up heads or tails. One flip, however, isn't going to tell you if the coin is weighted to always land the same.
<edit>I was still typing, it would seem, while Jill said much the same.

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