It's a judgement call. Some people seem to do fairly well with 'anything goes' linking.
In theory you will get better ranking with 'relevancy' or theme-to-theme linking.
In practice it depends on a lot of other factors as well- keyword focus, the number of competing pages, quite a few others.
Then theres the contrast between 'traffic trading' and 'SE linking', a whole other dimension which affects your profit.
Build one site with anything goes, build another with relevancy, and see which one makes more sales.
I've seen both work.
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