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Step 1: Optimize for Google. That should set up you up pretty well for the other SEs as also.
Step 2: If you happen to know some secret ways to game MSN, check that it won't be contrary to what helps you in Google and do it, if it does, go back to step 1.
I've found many spammy techniques work best with MSN, techniques I would never use since they would jeopardize my Google results.
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