Well, you can put the No Frames Tag anywhere after the first Frameset tag. If just doesn't make sense. Do yourself a favor. Put your No Frames content immediately under your first Frameset tag. The spiders will be happier, and your web site may just wind up ranking higher because of it.
Some people believe they are doing just that.
And on the next page we'll cover this topic in some more detail. Google, Frames, and Other Search Engines Recent reports surfaced from various search engine optimization consultants that Google and a few other engines were dropping support for No Frames content. A review of Spider-Food.net clients demonstrated that none of their web sites had been adversely effected, so I really can not confirm or deny this conclusion. However, the reports should not be taken lightly. What I do recommend against, however, is using a zero pixel frameset to take advantage of the No Frames tag.