Why does Volokh Conspiracy rank low in searches for "cheap apartment for sale in brazil"?

Today I received the following unsolicited e-mail, offering professional services to address what the sender perceives to be a serious problem with the Volokh Conspiracy, and the entire Washington Post Web site:

Dear webmaster of the www.washingtonpost.com,

I am Rahul from India working as a Business Developer. While I was searching the keyword "cheap apartment for sale in brazil" in Google, Your website is not appearing on top 10 organic searches.

I would like to say that, it can be possible to bring your website at the #1 position in Google.

If you are interested to see your website "washingtonpost.com" in #1 organic position on Google for other keywords too then I can help you. Do kindly inform us with your all targeted keywords for which you want to rank higher.

Skype me on my below ID so that we can discuss more about the process.

Waiting your positive reply

Best regards
Rahul [address omitted]

Initially, I was not inclined to take this e-mail seriously. First of all, in the search term that the writer used, "Brazil" was not capitalized. Second, "cheap" has a somewhat negative quality connotation, especially in a real estate context; "inexpensive" or "affordable" seem preferable. However, when I made the corrections, and ran a new Web search, The Washington Post's site still did very poorly, and the Volokh blog did even worse. Rather, all of the top 10 organic (non-paid) results were from real estate companies in Brazil, South America or Brazil, Ind.

I brought the problem to the attention of Eugene Volokh, who responded with two pieces of bad news: 1. His analysis of The Post's current marketing strategy is that the Brazilian real estate market in any form (South America or Indiana; apartments, houses, rentals or ownership) is a very low priority for The Post's management at present so it would be futile to ask them to adopt a systematic strategy for improving search results. 2. The VC's budget on Search Engine Optimization for 2015 has already been fully committed to two projects: "Somin, soccer/football/futbol" and "Oliver Wendell Holmes, incorrect/mistaken/wrong-headed/over-rated/bad." So apparently the VC bloggers are just going to have to solve the problem ourselves. Here is my contribution:

Have you seen the video of Brazilian women in bikinis playing footvolley on beach? Or the pictures of the "20 Hottest Brazilian Girls"?

It is possible, indeed likely, that some of the women discussed in the paragraph above know someone who is searching for a cheap apartment for sale in Brazil.

One cause of the housing problem in Brazil, as explained by VC's Ilya Somin, is that the national government destroyed thousands of homes in order to build now-useless stadiums for the World Cup. According to a report by The Post's Dom Phillips, Brazil has a shortage of 6.9 million housing units, and the socialist government's housing subsidy program has been far from sufficient to solve the problem. The challenge of finding cheap apartments for sale in Brazil is just one aspect of the housing shortage, exemplified by the many millions of people who live improvised houses in the slums (favelas) of Brazil's metropolises.

An endemic cause of the problem may be Brazil's weak performance in the protection of property rights. On a scale of 0 to 100, Brazil scores only a 50 for protection of property rights, according to the global Index of Economic Freedom. Globally, Brazil ranks 118th in economic freedom. According to the Cato Institute's Economic Freedom of the World report, Brazil's protection of property rights has improved this century. (On a 0-10 scale, 5.08 in 2000 and 6.0 in 2012.) Progress, but there is a long way to go. Perhaps the larger impediment is pervasive corruption, which is aggravated by the many corruption opportunities which result from extensive government control of economic activity.

London in the 1700s had its own favelas, as detailed in Mary Dorothy George's London Life in the 18th Century. Perhaps there are government programs which can palliate the problem, but the long-term solution is economic growth so that poor and middle-class people have the resources to buy good-quality housing, which will be supplied by housing entrepreneurs, unless the government imposes obstacles to housing construction.

In Liberty for Latin America: How to Undo Five Hundred Years of State Oppression, Alvaro Vargas Llosa identifies five principles of oppression in Latin America: corporatism, state mercantilism, privilege, wealth transfer and political law. Oppression existed in pre-Columbian times, and continues to the present, notwithstanding many changes in governments and in formal ideologies. He points out that in Brazil, it takes 67 business days and 15 procedures to start a small business; the cost is equal to 70 percent of per capita GDP. In the long term, the answer to the question of cheap apartments for sale in Brazil, and of a better standard of living for the people of Brazil and the rest of Latin America, is liberty and the rule of law.