Since whales have a large stake in Steemit as curators, and can't cash out immediately, they pretty much have to make sure a diverse amount of good content rises to the top. It's probably possible for a few larger fish to make quick money by upvoting one another but, they'd dilute their stakes over the long term if enough people noticed they're voting up a narrow range of content which might not always be high in quality.
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This is a good point. But are people paying enough attention to notice something like that? And how many would care even if they did?
I guess we'd have to hope enough people notice when the content quality goes down as the system readjusts itself like in Bitcoin mining.