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I'd count those as three links. I've been being a total bitch about this 3 links rule lately. Why? Because it seems like if I give an inch on this, the next site will have even more links and then when I reject it, I get argued with. I'm getting SICK of being argued with for rejecting sites (can you tell?) to my own link lists!
If I wanted that layout, I'd probably choose to link the banner and not the text. Just a personal preference I guess.
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