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@adamspelbring @jensimmons If it's an article, I think you could make a case for the headline being the most important heading on the page.
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@adamspelbring @jensimmons If it's a home page or a product site, the site title might be the most important thing.
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@adamspelbring @jensimmons Then, of course, there's the question of vacuous marketing headlines vs actually useful headlines.