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This is not what Medium advises in their formatting guide.

Headers: To set a header, select any text that isn't the title or subtitle and click the large "T" icon.

You are, howver, correct, when it comes to to SEO. Are you sure that this affects views? I've been writing here for 2 1/2 years, and until I was blacklisted had my stuff distributed all the time, at times reaching 40K views in an article.

https://help.medium.com/hc/en-us/articles/215194537

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