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Another factor is the amount
Another factor is the amount of catch-up there is to be done. I recently told a client with a newish site it would be almost impossible to get a fair ROI for my work, because he had chosen to do the entire site in flash. To SEO the site properly would require either rewriting the site completely, or coming up with a full no-flash version of the site.
And once that's done, you then need to optimise the content and build the links.
The rewrite of the site would logically be counted in the ROI calculations for the SEO work, but really it's a catch-up cost for a mistake made previously (because the developer forgot to mention that choosing a full flash site means poor rankings).