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Your question is not a yes or no question. I have a friend who makes 5-10% CTR but Google has no problem with it because she built her site up to that point over a period of several years. Their system also is good at detecting fraud and can see that her clicks are from a wide area around the world. They don't come from only a few IP addresses. I have heard from some that if the CTR looks legitimate to their system but is showing more than 2 clicks a person per session, then their system eliminates the extra clicks. I can not confirm this fact.
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