Examples in Google's GWO documentation have </noscript>
tags floating around free:
<h1>
<script>utmx_section("Headline")</script>
Welcome!
</noscript>
</h1>
That doesn't even look to me like valid HTML. Somebody's missing something -- either the example is missing the open <noscript>
tag or I'm missing the explanation of how this is supposed to work.