Define near... Reading the headline I was thinking in terms of AU, not millions of light years
While observable Universe will always be 93 billion light years in diameter, it is worth noting that everything is moving away from everything faster than gravity can counteract. That is, the Causally Disconnected (un-observable) Universe is inflating faster, the bigger it gets.
So a person that understands the topic should immediately understand we are talking about relatively close galaxy.
Sure, but a person who doesn't would receive the message more clearly if it were stated as "Supermassive black hole eruption near milky way". Otherwise I could write "Supermassive black hole eruption near New York" and be equally correct.
I suspect the potential for misunderstanding was the reason the headline was chosen in this form, however ...
I know research on priming has got some well deserved criticism, but there is no doubt basic framing works and this article either plays this effect for purpose or is scarily unaware of it.
That explains a lot of clickbait!
The purpose of the title of any article is to attract attention, so from that point you could say every title is clickbait.
Where I define "too far" (or actual clickbait) is when the title is dishonest about its contents or is purposefully omitting important information that makes the article much less interesting than the title suggests.
In this case the title was actually both truthful and contained relatively complete description of what is included in the article. Could they say "near Milky Way"? Well... they could, but "near Earth" is also factually correct.
And 12 million light years is actually quite close for any new supermassive black hole-related findings.
A lot of clickbait is technically correct including many of the dreaded "<n> <x> that <y> - you won't guess number <z>".