Is This Cloaking?

My new site displays 2 different versions of directory listings based on whether or not a specific cookie is set ...

Make sure you click this FIRST:

http://www.seopark.com/directory/23...nology/software

If you don't have a cookie set (which includes any spider, right?), that is the view you would get.

Now, click the "Return to Link Exchange Directory" link and then go back to the list page and refresh. This is how a normal user that accepts cookies would see the page when coming from the main directory.

So, is this considered cloaking? It has nothing to do with the IP or user agent. But, it is intentionally blocking access to some of the listing details by users without cookies or anyone not coming through the main directory page.

Yes it is. But since the only thing you are doing is to remove some information from the spiders and not do the more black-hat trick of feeding them a load of keywords, I'm sure you won't get into trouble.

Even Google cloaks in some way, by directing a first-time user to the appropriate local version of it's engine.

Gringo.