1 00:00:00,200 --> 00:00:03,640 Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles. 2 00:00:04,200 --> 00:00:06,519 In this episode, we're diving right back into the court 3 00:00:06,559 --> 00:00:08,960 documents and we're going to take a look at the 4 00:00:09,119 --> 00:00:14,320 expert witness report of doctor Bernard Jay Jansen, who is 5 00:00:14,359 --> 00:00:17,960 a professor at the College of Information of Sciences and 6 00:00:18,000 --> 00:00:22,559 Technology at penn State University, regarding the case of Virginia 7 00:00:22,679 --> 00:00:28,640 Roberts and Galaine Maxwell. Introduction. I have been retained by 8 00:00:28,640 --> 00:00:32,479 the law firm of Farmer Jaffey, Weissing, Edwards, Fistos and 9 00:00:32,640 --> 00:00:37,439 Layerman Pel to provide expert analysis and opinion on behalf 10 00:00:37,479 --> 00:00:43,520 of Miss Virginia Roberts in Virginia Roberts Plaintiff versus Glaiine Maxwell, Defendant. 11 00:00:43,799 --> 00:00:48,320 Two qualifications. I am a tenured full professor at the 12 00:00:48,320 --> 00:00:53,039 College of Information Sciences and Technology at the Pennsylvania State University, 13 00:00:53,359 --> 00:00:57,079 University Park, Pennsylvania, where I've been employed since two thousand 14 00:00:57,119 --> 00:01:00,439 and one. I am the director of the Information and 15 00:01:00,520 --> 00:01:04,879 Learning Laboratory at the College of Information Sciences and Technology 16 00:01:05,120 --> 00:01:08,599 at penn State University. I am also a principal scientist 17 00:01:08,680 --> 00:01:12,480 at the Cutter Computing Research Institute. I was a senior 18 00:01:12,480 --> 00:01:15,719 fellow at the Pew Internet and American Life Project, which 19 00:01:15,760 --> 00:01:19,079 is part of the Pew Research Center. From twenty ten 20 00:01:19,120 --> 00:01:23,680 to twenty twelve, I was also a university expert at 21 00:01:23,719 --> 00:01:28,799 the National Ground Intelligence Center from twenty eleven through twenty fourteen. 22 00:01:29,239 --> 00:01:32,640 Prior to my employment at the Pennsylvania State University, I 23 00:01:32,680 --> 00:01:35,640 was a lecturer in the Computer science program at the 24 00:01:35,760 --> 00:01:39,840 University of Maryland Asian Division for one year. Before that, 25 00:01:40,239 --> 00:01:43,760 I was an assistant professor and lecturer in the Department 26 00:01:43,799 --> 00:01:47,519 of Electrical Engineering and Computer Science at the United States 27 00:01:47,560 --> 00:01:52,480 Military Academy AKA West Point for three years. Number three. 28 00:01:52,879 --> 00:01:57,200 In addition to my academic credentials, my professional experience includes 29 00:01:57,280 --> 00:02:01,280 twenty years of practice in the US military, working primarily 30 00:02:01,319 --> 00:02:05,719 in a variety of technology related leadership positions. Number four. 31 00:02:06,439 --> 00:02:10,240 I have authored approximately two hundred and fifty academic publications 32 00:02:10,360 --> 00:02:14,840 focusing on the areas of web data, digital analytics, web analytics, 33 00:02:14,960 --> 00:02:20,240 web searching, web search engines, social media analytics, and related areas. 34 00:02:20,759 --> 00:02:25,759 Approximately two hundred of my publications address aspects of search analytics, 35 00:02:26,000 --> 00:02:31,800 web analytics, online advertising, search engines, or web searching. My 36 00:02:32,000 --> 00:02:36,400 recent research work focuses on online news analytics, which is 37 00:02:36,439 --> 00:02:41,080 the investigation of the online qualitative and quantitative attributes of 38 00:02:41,159 --> 00:02:45,120 news stories, along with other digital content. I am also 39 00:02:45,159 --> 00:02:48,960 the editor in chief of the academic journal Information Processing 40 00:02:49,360 --> 00:02:52,360 and Management, and I was previously the editor in chief 41 00:02:52,400 --> 00:02:56,840 for five years of the academic journal Internet Research. I 42 00:02:56,879 --> 00:03:00,759 have authored, co authored, or co edited for books including 43 00:03:00,800 --> 00:03:03,840 Web Search Public Searching of the Web two thousand and seven, 44 00:03:04,199 --> 00:03:08,879 Understanding User Web Interactions via Web Analytics two thousand and nine, 45 00:03:09,240 --> 00:03:13,319 and Understanding Sponsored Search twenty eleven. A copy of my 46 00:03:13,400 --> 00:03:17,120 complete curriculum, which includes a list of all publications I 47 00:03:17,159 --> 00:03:19,879 have authored in the past ten years, is attached as 48 00:03:19,919 --> 00:03:25,599 Appendix A number five. My fields of professional expertise include 49 00:03:25,639 --> 00:03:30,879 web analytics, search engines, web searching, social media, online advertising, 50 00:03:31,039 --> 00:03:34,240 and related areas. In the course of my academic career, 51 00:03:34,479 --> 00:03:36,960 I have worked with a variety of search engines and 52 00:03:37,120 --> 00:03:42,199 information searching applications in order to understand user searching behavior 53 00:03:42,520 --> 00:03:46,800 on the Web and in other environments. For example, as 54 00:03:46,919 --> 00:03:50,919 part of my master's degree program in computer science, I 55 00:03:51,039 --> 00:03:54,000 designed and coded a text based search engine. For my 56 00:03:54,080 --> 00:03:58,199 doctorate program in computer science, I developed a program interface 57 00:03:58,280 --> 00:04:00,960 for web search engines and implement entered it on the 58 00:04:01,000 --> 00:04:05,120 gigabyte Search engine. In subsequent research, I have worked with 59 00:04:05,240 --> 00:04:11,159 Microsoft Internet Information Services and Verity Commercial Searching Services six 60 00:04:11,680 --> 00:04:15,719 concerning user searching behaviors on the web using web analytics. 61 00:04:16,079 --> 00:04:19,399 I have worked directly with real user searching data from 62 00:04:19,519 --> 00:04:25,040 several search engines, including AOL, Alta, Vista, Dogpile, Excite, and 63 00:04:25,279 --> 00:04:29,920 MSN Live. I've also analyzed web data of visitor traffic 64 00:04:30,000 --> 00:04:33,439 and other attributes from a variety of websites and social 65 00:04:33,480 --> 00:04:37,839 media platforms. I have analyzed real user data from online 66 00:04:37,879 --> 00:04:42,920 search marketing campaigns and user referral traffic to websites. I 67 00:04:42,959 --> 00:04:47,040 have conduct research and teaching concerning aspects of websites and 68 00:04:47,120 --> 00:04:52,639 social media platforms, including keyword advertising. I've developed web analytics 69 00:04:52,680 --> 00:04:56,759 models and processes for analysis of business goals, and I 70 00:04:56,800 --> 00:05:00,279 have used web analytic data and commercial tools and both 71 00:05:00,279 --> 00:05:04,000 my research and my teaching, I've also conducted other research 72 00:05:04,160 --> 00:05:08,240 on users searching and related online behaviors. I have advised 73 00:05:08,279 --> 00:05:12,720 governmental agencies and companies in consulting and expert witnessing matters. 74 00:05:13,040 --> 00:05:15,680 A list of cases in which I have testified as 75 00:05:15,720 --> 00:05:18,720 an expert witness in a deposition or trial in the 76 00:05:18,759 --> 00:05:22,439 past four years is attached as the appendix be I 77 00:05:22,480 --> 00:05:25,920 am being compensated for my work on this case at 78 00:05:25,959 --> 00:05:29,160 the rate of three hundred dollars per hour. Number three 79 00:05:29,360 --> 00:05:35,279 Assignment and materials considered Number seven. In providing my expert opinion, 80 00:05:35,480 --> 00:05:37,879 I have been asked to respond to the following question 81 00:05:38,240 --> 00:05:41,800 Number eight, what is the dissemination of the statements from 82 00:05:41,879 --> 00:05:46,000 Miss Maxwell referring to Miss roberts declaration as untrue and 83 00:05:46,079 --> 00:05:48,800 lies from when the statements were made on the second 84 00:05:48,879 --> 00:05:52,000 of January twenty fifteen to the date that I filed 85 00:05:52,000 --> 00:05:56,600 this report Number nine. For brevity, I refer to references 86 00:05:56,639 --> 00:06:00,759 to the statement denoting Miss roberts declarations as untrue and lies. 87 00:06:01,319 --> 00:06:05,240 Any related accounts referring to those original statements or similar 88 00:06:05,279 --> 00:06:09,720 statements from Miss Maxwell or representatives referring to Miss Roberts 89 00:06:09,959 --> 00:06:13,319 as the statements made against Miss Roberts, the statements from 90 00:06:13,600 --> 00:06:18,120 Miss Maxwell's message, or the message from mister Gal Number ten. 91 00:06:18,879 --> 00:06:22,759 My analysis is based on my experience, training, knowledge, and 92 00:06:23,000 --> 00:06:27,920 education and is formed through the application of that experience, training, knowledge, 93 00:06:27,959 --> 00:06:32,560 and education in the principles of web data collection, web analytics, 94 00:06:32,720 --> 00:06:38,160 web search search engines, websites, web traffic analysis, and related 95 00:06:38,199 --> 00:06:43,040 market analysis. Number eleven. The materials that I considered in 96 00:06:43,079 --> 00:06:47,759 preparing this report are listed in Appendix see the Summary 97 00:06:47,800 --> 00:06:51,480 of opinions twelve. Based on my research and analysis in 98 00:06:51,480 --> 00:06:54,839 connection with this assignment, which is described in more detail 99 00:06:55,079 --> 00:06:59,040 in the body of this report, along with my own experience, training, knowledge, 100 00:06:59,079 --> 00:07:03,120 and education stated below, I have reached the following opinion 101 00:07:03,399 --> 00:07:07,800 number thirteen. Statements made against Miss Roberts have been disseminated 102 00:07:07,839 --> 00:07:11,079 to at least one hundred and fifteen online media or 103 00:07:11,120 --> 00:07:14,439 other sites in one hundred and seventy eight separate stories 104 00:07:14,680 --> 00:07:18,639 or articles with a combined sixty six million, nine hundred 105 00:07:18,639 --> 00:07:21,920 and nine thousand, nine hundred and sixty five potential unique 106 00:07:22,000 --> 00:07:26,000 visitors since January two, twenty fifteen, to the date that 107 00:07:26,040 --> 00:07:31,639 I filed this report inclusive fourteen. This is a conservative estimate, 108 00:07:31,879 --> 00:07:34,639 and it is more likely than not the statements made 109 00:07:34,639 --> 00:07:38,000 by Miss Maxwell against Miss Roberts have received a wider 110 00:07:38,040 --> 00:07:42,199 dissemination due to the factors such as a I used 111 00:07:42,199 --> 00:07:46,040 a set of online websites to measure dissemination, and it's 112 00:07:46,160 --> 00:07:49,680 reasonable that I have not located all references to the 113 00:07:49,720 --> 00:07:53,399 statements made against Miss Roberts on every website by the 114 00:07:53,439 --> 00:07:57,639 time of the submission of this report. B. I examined 115 00:07:57,720 --> 00:08:01,360 only online sources referencing the statement made against Miss Roberts, 116 00:08:01,519 --> 00:08:04,920 and not print or broadcast media dissemination of the statements 117 00:08:04,959 --> 00:08:08,800 made against Miss Roberts. See. I have not attempted to 118 00:08:08,800 --> 00:08:12,360 measure face to face dissemination of articles containing the statements 119 00:08:12,399 --> 00:08:15,759 against Miss Roberts. D. I do not have access to 120 00:08:15,839 --> 00:08:20,079 certain online sources where articles containing the statements against Miss 121 00:08:20,160 --> 00:08:24,800 Roberts may have been disseminated. E. There are possibly sites 122 00:08:24,879 --> 00:08:28,360 that have hosted the statements made against Miss Roberts that 123 00:08:28,480 --> 00:08:32,320 I cannot locate, or where the statements have been removed. 124 00:08:32,960 --> 00:08:36,120 F There are sites that hosted the articles containing the 125 00:08:36,120 --> 00:08:39,159 statements made against Miss Roberts where the visitor data is 126 00:08:39,200 --> 00:08:42,399 not accessible, or where I could not confirm the number 127 00:08:42,440 --> 00:08:46,799 of visitors. G. I did not consider the dissemination via 128 00:08:46,879 --> 00:08:50,759 social media platforms of articles containing the statements made against 129 00:08:50,799 --> 00:08:55,200 Miss Roberts. H. Many sites published multiple articles on multiple 130 00:08:55,279 --> 00:08:59,559 days that contained or referenced the statements made against Miss Roberts. 131 00:08:59,759 --> 00:09:03,600 How However, I did not include these multiple publication dates 132 00:09:03,600 --> 00:09:08,600 in calculating unique daily visitors. I. I did not include 133 00:09:08,720 --> 00:09:11,919 unique daily visitors to articles that link from the article 134 00:09:12,200 --> 00:09:15,159 till one or more of the articles containing the statements 135 00:09:15,200 --> 00:09:19,559 made against Miss Roberts Jay. Finally, I did not include 136 00:09:19,559 --> 00:09:22,919 the accounts of those who may have been searching and 137 00:09:23,000 --> 00:09:25,720 seen the statements made against Miss Roberts in the search 138 00:09:25,840 --> 00:09:32,440 results listing Part five. Background web analytics for traffic analysis fifteen. 139 00:09:32,919 --> 00:09:36,279 In the course of forming this opinion, I implemented numerous web 140 00:09:36,320 --> 00:09:40,679 analytics and related techniques commonly used in the industry. In 141 00:09:40,799 --> 00:09:44,039 order to more clearly discuss these techniques, I define the 142 00:09:44,080 --> 00:09:48,840 following terms. Direct traffic visitors to a website that come 143 00:09:48,879 --> 00:09:52,360 from entering a website link into a browser location eg. 144 00:09:52,600 --> 00:09:56,559 Not coming from a link or another website. Dissemination, the 145 00:09:56,600 --> 00:10:00,960 act of spreading, or the circulation of information or articles 146 00:10:02,320 --> 00:10:06,639 domain a specific Internet website that are administered as a 147 00:10:06,720 --> 00:10:11,480 unit and defined by an Internet Protocol address. Reach the 148 00:10:11,559 --> 00:10:15,320 percentage or number of people who visit a website out 149 00:10:15,360 --> 00:10:19,759 of the total targeted population. Referral traffic visitors to a 150 00:10:19,840 --> 00:10:23,720 site that come from websites other than search engines, repeat 151 00:10:23,799 --> 00:10:27,799 visits visitor traffic to a website in a given period 152 00:10:28,039 --> 00:10:30,960 that just includes multiple visits from the same set of 153 00:10:31,039 --> 00:10:35,120 IP addresses IE IP addresses with more than one visit 154 00:10:35,399 --> 00:10:38,639 provides account of the people who have visited a site 155 00:10:38,799 --> 00:10:41,759 more than once in a given period. An individual is 156 00:10:41,879 --> 00:10:46,039 usually defined by a combination of IP addresses and browser 157 00:10:46,360 --> 00:10:49,440 within a given period, but can also be defined by 158 00:10:49,559 --> 00:10:55,759 more sophisticated methods. Search engine a program and associated hardware 159 00:10:55,840 --> 00:11:00,200 and processes that allows people to find information on the web, 160 00:11:00,320 --> 00:11:04,320 typically via the submission of queries consisting of terms search 161 00:11:04,360 --> 00:11:07,960 traffic visitors to a site that come from search engines 162 00:11:08,399 --> 00:11:12,960 rather than from other websites, or via direct navigation search 163 00:11:13,679 --> 00:11:16,559 a submission of a query to a search engine, usually 164 00:11:16,559 --> 00:11:20,320 in the form of terms forming a query. Share sharing 165 00:11:20,360 --> 00:11:22,720 of an article or a web page, typically via some 166 00:11:22,919 --> 00:11:27,360 social media platform social media content that is shared via 167 00:11:27,480 --> 00:11:32,480 social media networking websites. Unique visits visitor traffic to a 168 00:11:32,480 --> 00:11:36,080 website within a given period that includes only the first 169 00:11:36,159 --> 00:11:41,159 visit IE. Subsequent visits are ignored, which excludes repeat visits, 170 00:11:41,320 --> 00:11:44,200 provides account of the individuals who have visited in a 171 00:11:44,279 --> 00:11:49,240 site in a given period. Unique daily visitors visitor traffic 172 00:11:49,279 --> 00:11:52,519 to a website who visits a site at least once 173 00:11:52,559 --> 00:11:55,759 in a given twenty four hour period. Each visitor to 174 00:11:55,799 --> 00:11:59,320 the site is counted once during the reporting period, which 175 00:11:59,360 --> 00:12:02,519 means it exc fludes repeat visits. Provides account of the 176 00:12:02,559 --> 00:12:05,440 individuals who have visited a site on a given day. 177 00:12:06,120 --> 00:12:09,799 Visits account of all the traffic to a website in 178 00:12:09,840 --> 00:12:14,120 a given period, including both unique and repeat visits. Web 179 00:12:14,200 --> 00:12:19,360 analytics the measurement, collection, analysis, and reporting of web data. 180 00:12:19,879 --> 00:12:21,720 All right, folks, we're going to wrap up right there, 181 00:12:21,879 --> 00:12:23,720 and in the next episode, we're going to pick up 182 00:12:23,879 --> 00:12:26,840 where we left off. All of the information that goes 183 00:12:26,879 --> 00:12:30,120 with this episode can be found in the description box. 184 00:12:30,960 --> 00:12:34,480 What's up, everyone, and welcome back to the Epstein Chronicles. 185 00:12:35,080 --> 00:12:37,480 In this episode, we're going to dive right back into 186 00:12:37,600 --> 00:12:41,080 that expert witness testimony that we were talking about in 187 00:12:41,120 --> 00:12:45,799 the last episode, So let's get back to it. Part six. 188 00:12:46,600 --> 00:12:51,960 Methodology sixteen. I was asked to determine the dissemination of 189 00:12:52,080 --> 00:12:56,879 articles containing the statements made against Miss Roberts seventeen. Informing 190 00:12:56,960 --> 00:13:02,080 my opinion, I utilized accepted web analytics and related methodologies 191 00:13:02,399 --> 00:13:06,399 in developing my assessment eighteen. To that end, I employed 192 00:13:06,480 --> 00:13:11,159 various publicly available online analytics services as well as some 193 00:13:11,240 --> 00:13:16,399 subscription based services. In conducting my research including Alexa, an 194 00:13:16,399 --> 00:13:21,080 online service that provides web traffic data and analysis. Compete 195 00:13:21,200 --> 00:13:25,399 an online service that provides web traffic data and analysis. 196 00:13:25,639 --> 00:13:29,200 Google Keyword Tool an online service that provides the number 197 00:13:29,200 --> 00:13:31,799 of searches for a given set of keywords in a 198 00:13:31,840 --> 00:13:35,960 given month on the Google search engine. Google Trends an 199 00:13:36,000 --> 00:13:40,080 online service that shows how often a particular term is 200 00:13:40,120 --> 00:13:43,840 relatively searched on the Google Search Engine in a given period. 201 00:13:44,600 --> 00:13:48,759 Similar Web an online service that provides web traffic data 202 00:13:48,960 --> 00:13:54,559 and analysis. Spyfu an online service providing search data and analytics, 203 00:13:54,600 --> 00:14:00,440 including for both paid IE advertisements and organic IE natural 204 00:14:01,080 --> 00:14:06,080 algorithmic channels. W three snoop an online service that provides 205 00:14:06,120 --> 00:14:10,480 web traffic data and analysis. Nineteen. These tools offer a 206 00:14:10,559 --> 00:14:14,360 variety of data and analysis services, and they are frequently 207 00:14:14,480 --> 00:14:19,679 utilized by industry professionals in the search engine optimization, web analytics, 208 00:14:19,720 --> 00:14:26,159 and search engine marketing fields for market customer and competitive analysis. Furthermore, 209 00:14:26,320 --> 00:14:29,720 where possible, I did my own assessments as outlined below. 210 00:14:30,039 --> 00:14:34,679 In order to validate the data and analysis results. Number twenty, 211 00:14:35,240 --> 00:14:39,399 I utilize search engines, primarily Google, ending to assess the 212 00:14:39,440 --> 00:14:43,799 dissemination of articles containing the statements made against Miss Roberts 213 00:14:44,759 --> 00:14:48,919 twenty one. Whenever possible, I use multiple data sources, which 214 00:14:48,960 --> 00:14:53,519 is a data verification technique known as triangulation, where one 215 00:14:53,639 --> 00:14:57,799 uses multiple and disparate sources of analysis and then compare 216 00:14:57,840 --> 00:15:01,720 the results from the separate analysis. If the results are similar, 217 00:15:01,919 --> 00:15:06,279 it reinforces the conclusion that the overall data analysis is valid. 218 00:15:07,440 --> 00:15:10,960 Number twenty two. In all of my assessments, I have 219 00:15:11,120 --> 00:15:14,399 used the most conservative numbers, meaning that I use the 220 00:15:14,399 --> 00:15:18,399 smallest value in arriving at the dissemination of articles containing 221 00:15:18,399 --> 00:15:22,039 the statements made against Miss Roberts. If I had employed 222 00:15:22,159 --> 00:15:26,360 this conservative estimate, the number of potential dissemination of articles 223 00:15:26,600 --> 00:15:29,919 containing the statements made against Miss Roberts would be one 224 00:15:30,039 --> 00:15:33,080 hundred and two million, seven hundred and forty thousand, eight 225 00:15:33,200 --> 00:15:38,360 hundred and sixteen daily unique visitors. Number twenty four. My 226 00:15:38,480 --> 00:15:42,440 analysis is based on my experience, training, knowledge, and education 227 00:15:43,000 --> 00:15:46,600 is formed through the application of that experience, training, knowledge, 228 00:15:46,879 --> 00:15:51,759 and education in the principles of web data collection, web analytics, 229 00:15:51,919 --> 00:15:57,080 web search search engines, websites, and related areas Number seven. 230 00:15:57,320 --> 00:16:01,200 Dissemination of the statements made against Miss Robbers twenty five. 231 00:16:01,879 --> 00:16:05,120 My opinion is that the articles containing the statements made 232 00:16:05,120 --> 00:16:08,240 against Miss Roberts have been disseminated to at least one 233 00:16:08,320 --> 00:16:11,799 hundred and fifteen online media and other sites in one 234 00:16:11,919 --> 00:16:15,440 hundred and seventy eight separate stories or articles with a 235 00:16:15,480 --> 00:16:19,200 combine sixty six million, nine hundred and nine thousand, nine 236 00:16:19,279 --> 00:16:24,120 hundred and sixty five unique daily visitors twenty six. This 237 00:16:24,159 --> 00:16:27,080 is a conservative estimate, and it's more likely than not 238 00:16:27,480 --> 00:16:31,360 the statements have received wider dissemination due to the factors 239 00:16:31,399 --> 00:16:34,440 such as A. I used a set of online websites 240 00:16:34,480 --> 00:16:38,440 one hundred and fifteen to calculate the dissemination of the articles, 241 00:16:38,799 --> 00:16:42,039 and it's reasonable that I have not located all references 242 00:16:42,039 --> 00:16:45,000 to the statements made against Miss Roberts by the time 243 00:16:45,039 --> 00:16:48,080 of the submission of this report, so there may be 244 00:16:48,080 --> 00:16:51,519 more sites with articles containing the statements made against Miss 245 00:16:51,600 --> 00:16:56,240 Roberts that are not included in my calculations. B. My 246 00:16:56,360 --> 00:17:00,639 focus of analysis was the online dissemination of the statements 247 00:17:00,919 --> 00:17:05,440 made against Miss Roberts. Therefore I examined only online sources 248 00:17:05,440 --> 00:17:08,839 and not dissemination of the statements made against Miss Roberts 249 00:17:08,920 --> 00:17:12,720 via print or broadcast media. It is reasonable to assume 250 00:17:12,960 --> 00:17:16,440 that the statements made against Miss Roberts were disseminated via 251 00:17:16,799 --> 00:17:21,119 these other channels. See. I have not attempted to measure 252 00:17:21,200 --> 00:17:25,680 face to face dissemination of the statements made against Miss Roberts. Therefore, 253 00:17:26,319 --> 00:17:29,480 these sources of dissemination are not included in the account 254 00:17:29,519 --> 00:17:33,759 of Daily Unique visitors. D. I did not have access 255 00:17:34,039 --> 00:17:37,359 to certain online sources where the statements against Miss Roberts 256 00:17:37,680 --> 00:17:42,359 may have been disseminated e g. Email messages, social media messages, 257 00:17:42,720 --> 00:17:46,640 articles behind firewalls, et cetera. Therefore, these sources are not 258 00:17:46,720 --> 00:17:51,039 included in account of Daily Unique visitors. E. There may 259 00:17:51,079 --> 00:17:54,279 be sites that hosted articles containing the statements made against 260 00:17:54,279 --> 00:17:58,319 Miss Roberts, where the articles have been removed. Therefore, I 261 00:17:58,440 --> 00:18:01,680 did not include these sites in my calculation of the 262 00:18:01,799 --> 00:18:06,200 unique daily visitors. F. There are sites where the visitor 263 00:18:06,279 --> 00:18:09,359 data is not accessible or where I could not reasonably 264 00:18:09,440 --> 00:18:12,640 check the number of visitors. In these cases, even though 265 00:18:12,640 --> 00:18:15,119 I had confirmed the site had posted one or more 266 00:18:15,240 --> 00:18:19,039 articles containing statements made against Miss Roberts, I did not 267 00:18:19,119 --> 00:18:23,359 include these sites in my calculation of the unique daily visitors. G. 268 00:18:24,240 --> 00:18:27,960 I did not consider the dissemination via social media platforms 269 00:18:28,000 --> 00:18:32,759 of articles containing the statements against Miss Roberts. H Many 270 00:18:32,799 --> 00:18:36,720 sites publish multiple articles on multiple days that contain or 271 00:18:36,759 --> 00:18:40,720 reference the statements made against Miss Roberts. However, I did 272 00:18:40,720 --> 00:18:43,839 not use these multiple articles from the same site with 273 00:18:43,920 --> 00:18:47,960 different publication dates in my calculations in determining the number 274 00:18:48,200 --> 00:18:51,319 of daily unique visitors who have been exposed to the 275 00:18:51,400 --> 00:18:55,839 articles containing the statements made against Miss Roberts. I I 276 00:18:56,000 --> 00:18:58,839 did not include articles that link to one or more 277 00:18:59,039 --> 00:19:02,519 of the articles containing the statements made against Miss Roberts. 278 00:19:02,920 --> 00:19:06,799 Unless the article directly referenced the statements made against Miss Roberts, 279 00:19:07,079 --> 00:19:11,039 I did not include it in my analysis. Jay. Finally, 280 00:19:11,480 --> 00:19:14,119 I did not include people who may have been searching 281 00:19:14,400 --> 00:19:16,920 and may have seen the statements made against Miss Roberts 282 00:19:16,960 --> 00:19:20,279 in the search results without needing to visit the actual 283 00:19:20,359 --> 00:19:25,599 articles posted on the websites. Number eight Methodology to determine 284 00:19:25,640 --> 00:19:29,880 the dissemination of the statements made against Miss Roberts twenty seven. 285 00:19:30,359 --> 00:19:32,839 I have been informed that the statements made against Miss 286 00:19:32,960 --> 00:19:36,519 Roberts were originally contained in an email message from Ross 287 00:19:36,519 --> 00:19:41,319 Gau of Acuity Reputation, acting on behalf of Miss Maxwell 288 00:19:41,720 --> 00:19:45,759 that was sent on January two, twenty fifteen, at eight 289 00:19:45,839 --> 00:19:49,359 thirty eight pm to based on the email addresses people 290 00:19:49,480 --> 00:19:53,039 at The Mail Online, The Independent, The Mirror, The Times 291 00:19:53,240 --> 00:19:57,240 and the BBC. The email message from mister gu contained 292 00:19:57,240 --> 00:20:00,519 the statements made against Miss Roberts. A scre greenshot of 293 00:20:00,559 --> 00:20:04,359 the email message is shown in Figure one twenty eight. 294 00:20:04,680 --> 00:20:08,880 Figure one email message from Roscale containing the statements made 295 00:20:09,079 --> 00:20:14,480 against Miss Roberts thirty Additionally, on January eighth, twenty fifteen, 296 00:20:14,920 --> 00:20:19,319 agents reportedly acting on behalf of Miss Maxwell made statements 297 00:20:19,359 --> 00:20:21,880 that the allegations against her were a web of lies 298 00:20:22,119 --> 00:20:25,519 and deceit, which are similar to the statements made against 299 00:20:25,519 --> 00:20:30,640 Miss Roberts in the message from mister Gal thirty one. Similarly, 300 00:20:30,880 --> 00:20:35,880 on February first, twenty fifteen, agents reportedly acting on behalf 301 00:20:35,960 --> 00:20:39,440 of Miss Maxwell made statements that the allegations against her 302 00:20:39,559 --> 00:20:42,720 were a web of lies and deceit, which are similar 303 00:20:42,759 --> 00:20:45,559 to the statements made against Miss Roberts in the message 304 00:20:45,599 --> 00:20:51,200 from mister Gal thirty one. Similarly, on February first, twenty fifteen, 305 00:20:51,559 --> 00:20:56,440 like statements were quoted as these allegations are untrue and defamatory, 306 00:20:56,799 --> 00:20:59,559 which are similar to the statements made against Miss Roberts 307 00:20:59,599 --> 00:21:03,880 in the metassage from mister Gal thirty two based on 308 00:21:03,960 --> 00:21:08,519 my investigation and research. News stories, articles and postings containing 309 00:21:08,559 --> 00:21:12,440 direct reference to or quotes from the statements made against 310 00:21:12,440 --> 00:21:16,799 Miss Roberts appeared the same day, January two, twenty fifteen 311 00:21:17,240 --> 00:21:20,960 as the email from mister Gal, with several news organizations 312 00:21:20,960 --> 00:21:25,319 and other sites publishing other articles containing direct reference to 313 00:21:25,519 --> 00:21:29,119 or quotes from the statements made against Miss Roberts in 314 00:21:29,160 --> 00:21:33,640 the immediate following days. News articles containing direct reference to 315 00:21:33,880 --> 00:21:37,240 or quotes of the statements made against Miss Roberts have 316 00:21:37,400 --> 00:21:41,160 continued to appear in news articles and other postings nearly 317 00:21:41,240 --> 00:21:44,200 up to the date that I submitted this report Number 318 00:21:44,279 --> 00:21:47,960 thirty three. A timeline of events relating to the dissemination 319 00:21:48,160 --> 00:21:51,440 of the statements made against Miss Roberts is shown in Fig. 320 00:21:51,640 --> 00:21:56,160 Two thirty four. Fig. Two Timeline of events relating to 321 00:21:56,200 --> 00:21:59,599 the dissemination of the statements made against Miss Roberts from 322 00:21:59,680 --> 00:22:04,960 Jijanuary second, twenty fifteen onwards. Number thirty five concerning the 323 00:22:05,000 --> 00:22:08,519 procedure employed and determining the dissemination of the statements made 324 00:22:08,519 --> 00:22:12,960 against Miss Roberts. Nearly every major news site that I investigated, 325 00:22:13,240 --> 00:22:16,200 along with other specific news sites in the United States 326 00:22:16,240 --> 00:22:20,640 the United Kingdom, Canada and Australia, as well as other countries, 327 00:22:20,720 --> 00:22:23,759 have carried some aspects of the overall story related to 328 00:22:23,799 --> 00:22:27,359 Miss Roberts and Dora Maxwell or other parties that are 329 00:22:27,400 --> 00:22:31,119 involved thirty six. In fact, there are tens of thousands 330 00:22:31,119 --> 00:22:34,519 of news articles and postings concerning the general story from 331 00:22:34,640 --> 00:22:39,440 news outlets worldwide, with combined potential viewership in the multimillions 332 00:22:39,559 --> 00:22:42,880 as searches on the major search engines such as Google 333 00:22:42,920 --> 00:22:47,119 and Bing's show thirty seven. However, I was not interested 334 00:22:47,119 --> 00:22:50,279 in news articles that just discussed the story in general 335 00:22:50,480 --> 00:22:53,519 or other aspects of the story. Also, I was not 336 00:22:53,559 --> 00:22:56,839 interested in those articles where Miss Maxwell or those acting 337 00:22:56,839 --> 00:23:00,000 on her behalf such as mister Gall would just generally 338 00:23:00,160 --> 00:23:04,400 deny the allegations in the complaint. I was specifically interested 339 00:23:04,680 --> 00:23:08,119 in only those articles that reference directly or quoted the 340 00:23:08,160 --> 00:23:12,160 statements made against Miss Roberts in the January second, twenty 341 00:23:12,279 --> 00:23:16,759 fifteen email message from mister Goll to Miss Maxwell's subsequent 342 00:23:16,799 --> 00:23:21,039 confirmation of the statements or similar statements as those in 343 00:23:21,079 --> 00:23:25,279 the message from mister Goal. Naturally, this narrow focus is 344 00:23:25,319 --> 00:23:29,079 a smaller subset of news articles than are the articles 345 00:23:29,119 --> 00:23:33,880 addressing the overall story number thirty eight. To isolate these 346 00:23:34,000 --> 00:23:37,240 articles of interest, I generated a series of ten queries 347 00:23:37,440 --> 00:23:41,240 that specifically targeted news articles from the case that address 348 00:23:41,279 --> 00:23:45,200 the statements made against Miss Maxwell E. G. Glenn Maxwell's 349 00:23:45,240 --> 00:23:48,519 Obvious Lies. To retrieve a set of articles that directly 350 00:23:48,559 --> 00:23:52,240 related to the statements made against Miss Roberts, I employed 351 00:23:52,240 --> 00:23:56,480 a modified snowball technique, starting with one seed query, adding 352 00:23:56,599 --> 00:23:59,960 and modifying terms until I was not receiving new results. 353 00:24:00,359 --> 00:24:04,240 I also located some articles via navigating from the set 354 00:24:04,279 --> 00:24:08,240 of retrieved articles thirty nine. I set the search rage 355 00:24:08,279 --> 00:24:12,799 down from January second, twenty fifteen onward, so articles prior 356 00:24:12,839 --> 00:24:15,920 to that date were not included in the search results. 357 00:24:16,160 --> 00:24:19,440 For each article used in my analysis, I also verified 358 00:24:19,440 --> 00:24:22,440 the date that the article was published to ensure it 359 00:24:22,519 --> 00:24:26,720 was published on or after January second, twenty fifteen, and 360 00:24:26,799 --> 00:24:30,400 that the articles directly referenced in some way the statements 361 00:24:30,440 --> 00:24:34,440 made against Miss Roberts forty. An example of search engine 362 00:24:34,440 --> 00:24:38,160 results in response to one of those queries is shown 363 00:24:38,480 --> 00:24:42,880 in Fig. Three forty one. Figure three Google new search 364 00:24:42,960 --> 00:24:46,400 results for the search Glenn Maxwell's Obvious Lies, with the 365 00:24:46,480 --> 00:24:51,799 date delimiter beginning on January second, twenty fifteen. Forty two. 366 00:24:52,119 --> 00:24:55,480 I then personally verified that each article by reviewing each 367 00:24:55,599 --> 00:24:59,200 article used in my analysis directly referenced in some way 368 00:24:59,559 --> 00:25:03,240 the state it's made against Miss Roberts. Forty three, So 369 00:25:03,559 --> 00:25:06,680 articles relating to the overall story that did not mention 370 00:25:06,839 --> 00:25:10,599 Miss Maxwell's statements made against Miss Roberts were not included 371 00:25:10,920 --> 00:25:14,759 in the analysis. Articles relating to the overall story that 372 00:25:15,079 --> 00:25:18,880 referred to Miss Maxwell simply denying the charges were not included. 373 00:25:19,319 --> 00:25:23,319 Forty four. I also personally performed a site search of 374 00:25:23,480 --> 00:25:28,000 the top fifteen online media sites worldwide of articles related 375 00:25:28,079 --> 00:25:31,240 to the case, and I reviewed the results to identify 376 00:25:31,519 --> 00:25:34,559 if any of these articles referred to the statements against 377 00:25:34,559 --> 00:25:38,559 Miss Roberts. I also did the same for many countries 378 00:25:38,599 --> 00:25:42,319 specific news sites in the United States, United Kingdom, Canada, 379 00:25:42,359 --> 00:25:45,759 and Australia. Forty five. In the end, I had a 380 00:25:45,799 --> 00:25:48,720 set of one hundred and seventy eight online news and 381 00:25:48,799 --> 00:25:53,440 other articles from January two, twenty fifteen, to the date 382 00:25:53,519 --> 00:25:57,160 that I filed the report that specifically referenced the statements 383 00:25:57,200 --> 00:26:01,200 made against Miss Roberts. To conduct my analysis, as outlined below, 384 00:26:02,519 --> 00:26:05,559 each of these one hundred and seventy eight online articles 385 00:26:05,680 --> 00:26:08,799 was posted online. The one hundred and seventy eight online 386 00:26:08,839 --> 00:26:12,920 articles were distributed among one hundred and fifteen unique domain 387 00:26:12,960 --> 00:26:17,799 websites IE. Some websites posted multiple articles that contained the 388 00:26:17,839 --> 00:26:21,680 statements made against Miss Roberts forty seven. As seen from 389 00:26:21,680 --> 00:26:24,759 the list of domains that have published articles or stories 390 00:26:24,759 --> 00:26:28,480 containing references to the statement made against Miss Roberts, many 391 00:26:28,519 --> 00:26:32,559 of these domains are those of major news organizations or sources, 392 00:26:32,920 --> 00:26:38,680 including AOL News, BBC, Huvington Boast, International Business Time, Irish Times, 393 00:26:38,960 --> 00:26:43,519 MSN News, National Inquirer, New York Daily News, New Zealand Herald, 394 00:26:43,799 --> 00:26:48,160 Page six, Radar Online, Reuters, The Daily Beast, The Daily Mail, 395 00:26:48,519 --> 00:26:52,359 The Express, The Guardian, The Mirror, The Sun, The Telegraph, 396 00:26:52,599 --> 00:26:56,599 Yahoo News, et cetera. Forty eight. I then used a 397 00:26:56,640 --> 00:27:00,599 variety of web analytics, traffic services, and other sources to 398 00:27:00,720 --> 00:27:04,039 get the unique daily visitor traffic for each of these domains. 399 00:27:04,480 --> 00:27:08,119 I use multiple services when available to verify the unique 400 00:27:08,200 --> 00:27:11,400 daily visitor traffic for each of these domains, as the 401 00:27:11,440 --> 00:27:15,359 traffic services may use different techniques to arrive at their 402 00:27:15,400 --> 00:27:19,920 traffic numbers. Forty nine In some cases, conflicting unique daily 403 00:27:20,039 --> 00:27:24,079 visitor traffic numbers. I utilize the most conservative ie smallest 404 00:27:24,160 --> 00:27:27,839 number fifty. In cases where I determined I couldnot get 405 00:27:28,000 --> 00:27:31,599 unique daily visitor traffic numbers or the unique daily visitor 406 00:27:31,680 --> 00:27:34,799 traffic was not reliable in my opinion, I did not 407 00:27:34,839 --> 00:27:38,559 include the unique daily visitor traffic numbers for that domain 408 00:27:38,799 --> 00:27:42,480 in the numbers. This usually occurred for the sites with 409 00:27:42,599 --> 00:27:45,559 a smaller number of daily visitors or sites with an 410 00:27:45,559 --> 00:27:50,319 extremely large number of daily visitors. Fifty one Unique daily 411 00:27:50,519 --> 00:27:54,920 visitors measures as an industry standard web analytic metric for 412 00:27:55,119 --> 00:27:58,240 measuring people that visit a website in a given period, 413 00:27:58,480 --> 00:28:01,119 such as a week, a month, as there are normal 414 00:28:01,200 --> 00:28:06,680 daily fluctuations. Fifty two. Table one shows the unique visitors 415 00:28:06,720 --> 00:28:10,519 traffic for the listed domains that posted articles or stories 416 00:28:10,640 --> 00:28:14,599 referencing the statements made against Miss Roberts, and the associated 417 00:28:14,920 --> 00:28:18,720 unique daily visitor traffic for each of those domains, along 418 00:28:18,759 --> 00:28:22,160 with a number of articles containing the statements made against 419 00:28:22,160 --> 00:28:25,559 Miss Roberts posted on that site. All right, folks, we're 420 00:28:25,599 --> 00:28:27,920 gonna wrap up this episode here and in the next 421 00:28:27,920 --> 00:28:31,319 episode we're gonna pick up where we left off. All 422 00:28:31,359 --> 00:28:33,920 of the information that goes with this episode can be 423 00:28:34,000 --> 00:28:38,880 found in the description box. What's up, everyone, and welcome 424 00:28:38,920 --> 00:28:42,640 back to the Epstein Chronicles. In this episode, we're diving 425 00:28:42,720 --> 00:28:46,680 right back into the expert Witness Report of Bernard Jay 426 00:28:46,799 --> 00:28:53,119 Janssen Number fifty three. Table one domains that published articles 427 00:28:53,200 --> 00:28:56,440 or stories containing the statements made against Miss Roberts, with 428 00:28:56,519 --> 00:29:00,319 the domain's number of unique daily visitors and the number 429 00:29:00,319 --> 00:29:04,279 of articles containing the statements made against Miss Roberts published 430 00:29:04,359 --> 00:29:08,359 on that domain from January two, twenty fifteen, to the 431 00:29:08,440 --> 00:29:12,039 date that I filed this report fifty four. I used 432 00:29:12,119 --> 00:29:16,240 each domain's unique daily visitor account to calculate the dissemination 433 00:29:16,720 --> 00:29:19,839 of the articles containing the statements against Miss Roberts to 434 00:29:20,039 --> 00:29:24,400 various websites and potentially visitors to that site, i e. 435 00:29:24,519 --> 00:29:27,599 As visitors to the news sites. These individuals could have 436 00:29:27,640 --> 00:29:31,160 been exposed to the articles containing the statements made against 437 00:29:31,200 --> 00:29:35,440 Miss Roberts using the unique daily visitor number only once 438 00:29:35,559 --> 00:29:39,559 for each domain, regardless whether that domain published more than 439 00:29:39,640 --> 00:29:43,519 one article referring to the statements made against Miss Roberts 440 00:29:44,279 --> 00:29:49,000 Part eleven, Number fifty five. Based on my analysis as 441 00:29:49,039 --> 00:29:52,480 outlined above, my opinion is that the statements against Miss 442 00:29:52,599 --> 00:29:55,839 Roberts have been disseminated to at least one hundred and 443 00:29:55,960 --> 00:30:00,640 fifteen online media and other sites one hundred in seventy 444 00:30:00,680 --> 00:30:04,400 eight stories or articles with a combined sixty six million, 445 00:30:04,640 --> 00:30:07,599 nine hundred and nine thousand, nine hundred and sixty five 446 00:30:08,000 --> 00:30:12,440 more than sixty six million unique daily visitor traffic. Fifty six. 447 00:30:13,079 --> 00:30:15,079 I note that for many of the one hundred and 448 00:30:15,160 --> 00:30:19,240 seventy eight articles containing the statements made against Miss Roberts, 449 00:30:19,319 --> 00:30:21,160 one could get the gist of the story of the 450 00:30:21,240 --> 00:30:25,480 article directly from the article headline. I point this out 451 00:30:25,720 --> 00:30:29,200 as it's well known that people skim online news sites, 452 00:30:29,319 --> 00:30:32,599 so titles such as these would have substantial impact on 453 00:30:32,720 --> 00:30:36,400 visitors to that site. Fifty seven. This is a conservative 454 00:30:36,519 --> 00:30:40,160 estimate and more likely than not articles containing the statements 455 00:30:40,200 --> 00:30:44,000 made against Miss Roberts have been disseminated to more individuals. 456 00:30:44,480 --> 00:30:48,200 Ten why the estimate is low fifty eight. This sixty 457 00:30:48,200 --> 00:30:50,799 six million, nine hundred and nine thousand, nine hundred and 458 00:30:50,880 --> 00:30:55,200 sixty five individual unique daily traffic is a conservative estimate, 459 00:30:55,480 --> 00:30:58,160 and it is more likely than not the statements have 460 00:30:58,240 --> 00:31:03,680 received wider dissemination due to factors such as a. Although 461 00:31:03,839 --> 00:31:08,160 I spend a considerable effort to locate published articles that 462 00:31:08,240 --> 00:31:11,799 contain the statements made against Miss Roberts. It's reasonable to 463 00:31:11,880 --> 00:31:15,200 assume that I have not located all such articles by 464 00:31:15,240 --> 00:31:18,839 the time of the submission of this report, so there 465 00:31:18,839 --> 00:31:22,400 are possibly more sites with articles containing the statements made 466 00:31:22,440 --> 00:31:26,079 against Miss Roberts that are not included in my calculations, 467 00:31:26,279 --> 00:31:30,640 which would increase the dissemination of the articles b. The 468 00:31:30,680 --> 00:31:34,559 focus of my analysis was the dissemination of online articles 469 00:31:34,759 --> 00:31:38,160 containing the statements made against Miss Roberts, and I examined 470 00:31:38,319 --> 00:31:42,680 only online sources and not print broadcast media. Many of 471 00:31:42,680 --> 00:31:46,720 the media outlets that I did identify have considerable print 472 00:31:46,799 --> 00:31:51,519 distribution which are not included in my calculations, such as, 473 00:31:51,559 --> 00:31:56,000 for example, the Sun print circulation one million, seven hundred 474 00:31:56,000 --> 00:31:58,759 and forty one thousand, eight hundred and thirty eight, Daily 475 00:31:58,759 --> 00:32:02,599 Mail print circulation one million, five hundred and sixty two thousand, 476 00:32:02,720 --> 00:32:06,519 three hundred and sixty one, the Daily Telegraph print circulation 477 00:32:06,880 --> 00:32:09,640 four hundred and seventy two thousand, nine hundred and thirty six, 478 00:32:10,039 --> 00:32:13,480 The Times print circulation four hundred and two thousand, seven 479 00:32:13,599 --> 00:32:17,799 hundred and fifty two, The Guardian print circulation one hundred 480 00:32:17,839 --> 00:32:21,559 and sixty one thousand, one hundred and fifty two see 481 00:32:21,599 --> 00:32:24,799 In my analysis, I did not attempt to measure face 482 00:32:24,839 --> 00:32:28,799 to face dissemination that may have occurred after individuals may 483 00:32:28,799 --> 00:32:32,000 have read articles containing the statements made against Miss Roberts, 484 00:32:32,240 --> 00:32:36,359 which would increase the count D. Naturally, I cannot access 485 00:32:36,400 --> 00:32:39,880 certain online sources where the statements made against Miss Roberts 486 00:32:40,000 --> 00:32:44,319 may have been disseminated e. Gmail messages, social media messages, 487 00:32:44,400 --> 00:32:48,279 articles behind firewalls, et cetera. Therefore, these numbers are not 488 00:32:48,319 --> 00:32:53,480 included in my calculations. E. Also, there are possibly sites 489 00:32:53,480 --> 00:32:56,759 that have hosted articles containing the statements against Miss Roberts, 490 00:32:56,880 --> 00:32:59,839 where the articles have been removed. Therefore they are not 491 00:33:00,079 --> 00:33:04,319 included in my calculations. F For sites where more than 492 00:33:04,319 --> 00:33:08,079 one article containing the statements made against Miss Roberts are posted, 493 00:33:08,319 --> 00:33:11,359 but where I could not locate or not determine reliable 494 00:33:11,480 --> 00:33:14,839 daily unique visitor traffic, I have not included these sites 495 00:33:14,839 --> 00:33:18,200 in my calculations. There are fifty nine of the one 496 00:33:18,279 --> 00:33:21,880 hundred and fifteen fifty one point three percent, to be precise, 497 00:33:22,240 --> 00:33:25,839 where I could not get or not get verifiable traffic data. 498 00:33:26,359 --> 00:33:30,119 For example, the traffic numbers for the MSN News, Microsoft 499 00:33:30,319 --> 00:33:33,720 and Yahoo news are not separated by news and other 500 00:33:33,759 --> 00:33:37,160 services such as search, so I did not include these 501 00:33:37,200 --> 00:33:39,839 in the number of people to which the articles containing 502 00:33:39,880 --> 00:33:44,559 the statement made against were disseminated. G I did not 503 00:33:44,599 --> 00:33:48,119 include the dissemination of articles containing the statements made against 504 00:33:48,119 --> 00:33:52,279 Miss Roberts directly to social media platforms. However, many of 505 00:33:52,279 --> 00:33:56,279 the articles containing the statements made against Miss Roberts include 506 00:33:56,400 --> 00:33:59,359 counts of the number of times that individuals shared the 507 00:33:59,440 --> 00:34:02,880 article to a social media network, as shown in Table two. 508 00:34:04,480 --> 00:34:07,319 As shown in Table two, the articles containing the statements 509 00:34:07,359 --> 00:34:10,360 made against Miss Roberts have been shared thirty three thousand, 510 00:34:10,559 --> 00:34:14,679 seven hundred and fifty eight times, mostly on Facebook. Given 511 00:34:14,760 --> 00:34:17,360 that the medium number of Facebook friends is two hundred, 512 00:34:17,679 --> 00:34:21,159 this equates to a possible six million, seven hundred and 513 00:34:21,159 --> 00:34:24,639 fifty one thousand, six hundred individuals, in addition to the 514 00:34:24,719 --> 00:34:28,400 thirty three thousand, seven hundred and fifty eight individuals who 515 00:34:28,480 --> 00:34:31,679 originally shared the articles, to which the articles containing the 516 00:34:31,719 --> 00:34:35,719 statements made against Miss Roberts could have been disseminated, assuming 517 00:34:35,760 --> 00:34:39,239 these individuals are all unique and have not already read 518 00:34:39,280 --> 00:34:42,920 one of the articles. However, I did not include these 519 00:34:42,960 --> 00:34:47,800 social media shares in my calculations. Since news articles viewing 520 00:34:47,920 --> 00:34:51,760 follows a power law distribution, there is no direct linear 521 00:34:52,079 --> 00:34:55,880 ratio of number of social media shares to readership. There 522 00:34:56,079 --> 00:34:59,920 is published research that does report average views of an 523 00:35:00,119 --> 00:35:03,679 article on a news website and also average social media 524 00:35:03,719 --> 00:35:07,360 shares in direct calculation with the numbers from the article 525 00:35:07,760 --> 00:35:11,239 twenty three article views per social media share. Using thirty 526 00:35:11,239 --> 00:35:14,239 three thousand, seven hundred and fifty eight social media shares, 527 00:35:14,679 --> 00:35:17,840 this would be seven hundred and seventy six thousand, four 528 00:35:17,880 --> 00:35:21,800 hundred and thirty four article views. However, this ratio would 529 00:35:21,880 --> 00:35:25,360 vary by website, number of daily unique visitors, types of 530 00:35:25,400 --> 00:35:31,320 news articles, time of accumulating shares, and possibly other factors. Plus, 531 00:35:31,480 --> 00:35:34,400 this number would not account for the people receiving the 532 00:35:34,400 --> 00:35:38,079 social media share that viewed the title post and snippet 533 00:35:38,159 --> 00:35:40,320 but did not click on the shared to view the 534 00:35:40,440 --> 00:35:45,880 article on the website, thereby undercounting views of the articles. Also, 535 00:35:46,039 --> 00:35:49,119 given the topical nature of the underlying news story, one 536 00:35:49,119 --> 00:35:52,880 could expect lower social media sharing but higher article viewing, 537 00:35:53,119 --> 00:35:56,039 as people will tend to read articles on such topics 538 00:35:56,119 --> 00:35:59,480 privately but not share on social media, so I would 539 00:35:59,519 --> 00:36:02,960 expect this social media number itself to be an undercount 540 00:36:03,559 --> 00:36:06,400 h I did not include articles that link to one 541 00:36:06,440 --> 00:36:09,920 of the articles containing statements made by Miss Roberts in 542 00:36:09,960 --> 00:36:14,719 my calculations of dissemination. Unless the article directly mentioned the 543 00:36:14,760 --> 00:36:17,800 statements made against Miss Roberts, I did not include that 544 00:36:17,920 --> 00:36:23,159 article in my calculations. So unless the linking article actually mentioned, referenced, 545 00:36:23,239 --> 00:36:26,400 or quoted the statements made against Miss Roberts, I did 546 00:36:26,400 --> 00:36:30,639 not include it in my calculations. Many sites published multiple 547 00:36:30,719 --> 00:36:34,679 articles on multiple days that quoted or referenced the statements 548 00:36:34,679 --> 00:36:37,800 made against Miss Roberts. However, I did not use these 549 00:36:37,880 --> 00:36:41,880 multiple publication dates from the same site in my calculations 550 00:36:42,079 --> 00:36:45,639 of unique visitor traffic. If a domain published only one 551 00:36:45,760 --> 00:36:49,679 article containing the statements against Miss Roberts, then I directly 552 00:36:49,800 --> 00:36:53,039 used the unique daily visitor number. If a domain published 553 00:36:53,079 --> 00:36:57,159 multiple articles concerning the statements against Miss Roberts, I did 554 00:36:57,199 --> 00:37:00,719 not count the traffic for the subsequent articles containing the 555 00:37:00,760 --> 00:37:04,840 statements made against Miss Roberts, even though research shows that 556 00:37:04,920 --> 00:37:09,000 repeat traffic to websites is generally only about thirty percent, 557 00:37:09,400 --> 00:37:13,119 meaning that thirty percent of the traffic would be unique. However, 558 00:37:13,480 --> 00:37:16,639 I was not comfortable using this figure given the nature 559 00:37:16,679 --> 00:37:19,960 of these sites, which might have higher repeat visitors day 560 00:37:20,000 --> 00:37:23,719 to day. Therefore, I did not include the unique visitors 561 00:37:23,840 --> 00:37:28,079 to multiple articles in my calculations. Finally, I did not 562 00:37:28,199 --> 00:37:30,840 include the count of people who may have been searching 563 00:37:31,199 --> 00:37:34,079 and may have seen the statements made against Miss Roberts 564 00:37:34,119 --> 00:37:37,639 in the search results without needing to visit the actual articles, 565 00:37:37,920 --> 00:37:43,000 as shown in Figure four. Fig four example of search 566 00:37:43,039 --> 00:37:46,320 results with the statements made against Miss Roberts appearing in 567 00:37:46,360 --> 00:37:50,679 the results snippets requiring no need to visit the articles themselves. 568 00:37:52,000 --> 00:37:56,039 Accuracy of the traffic numbers, and additional verification fifty nine 569 00:37:56,519 --> 00:37:59,800 concerning the accuracy of the analysis. The number of domains 570 00:37:59,800 --> 00:38:03,519 where the statements made against Miss Roberts have been disseminated 571 00:38:03,639 --> 00:38:07,559 is reliable as this is straightforward to verify, ie the 572 00:38:07,639 --> 00:38:10,320 article is either posted on a site or it is not. 573 00:38:10,920 --> 00:38:14,920 If anything, that is an undercount, as some domains, for example, 574 00:38:15,000 --> 00:38:18,519 may have removed such articles, making them no longer available. 575 00:38:19,199 --> 00:38:21,960 There are possibly articles containing the statements that I have 576 00:38:22,039 --> 00:38:24,480 not been able to locate by the time that I 577 00:38:24,559 --> 00:38:29,280 submit this report. Sixty concerning traffic numbers for domains. A 578 00:38:29,360 --> 00:38:33,639 unique visitor is typically identified by an identifier stored in 579 00:38:33,679 --> 00:38:37,519 a text file which is based on an individual computers browser. 580 00:38:37,880 --> 00:38:42,599 Although more sophisticated methods are also being used. In locating 581 00:38:42,599 --> 00:38:47,039 traffic numbers for the domains, I used multiple services when available, 582 00:38:47,199 --> 00:38:50,960 and attempted to verify via other sources. In case with 583 00:38:51,159 --> 00:38:55,280 varying traffic data, I utilize the most conservative IE's smallest 584 00:38:55,360 --> 00:38:59,920 number available, sixty one. I also verified findings from my 585 00:39:00,000 --> 00:39:03,719 my analysis via other methods and my own experience in training. 586 00:39:04,079 --> 00:39:07,760 For example, there are periods of increased publishing of articles 587 00:39:07,920 --> 00:39:11,679 containing the statements made against Miss Roberts and related stories. 588 00:39:12,320 --> 00:39:16,440 One would expect increases in associated searching during these periods. 589 00:39:16,960 --> 00:39:20,239 Using the Google keyword tool, which provides search volume for 590 00:39:20,280 --> 00:39:24,320 search queries by month, I examined search volume for January 591 00:39:24,400 --> 00:39:27,400 twenty fifteen to the date that I filed this report. 592 00:39:27,880 --> 00:39:31,119 There was fifty four thousand, five hundred and eighteen percent 593 00:39:31,199 --> 00:39:35,440 increase in search volume for the keywords Virginia Roberts and 594 00:39:35,559 --> 00:39:39,280 Glenn Maxwell and January of twenty fifteen relative to the 595 00:39:39,320 --> 00:39:42,639 prior seven months in the US, and forty four thousand, 596 00:39:42,920 --> 00:39:46,400 eight hundred and twenty two percent increase for the United Kingdom. 597 00:39:46,599 --> 00:39:50,719 In January twenty fifteen relative to the prior seven months. 598 00:39:51,199 --> 00:39:54,000 This is in line with the increase in posting of 599 00:39:54,119 --> 00:39:57,280 articles during the same month, so once he is the 600 00:39:57,320 --> 00:40:00,920 expected increase in searching for key t terms based on 601 00:40:01,000 --> 00:40:05,800 the increase of posting articles. Sixty two. Figure five shows 602 00:40:06,039 --> 00:40:09,840 increase in searching volume in January twenty fifteen for the 603 00:40:09,960 --> 00:40:14,400 US and UK relative to the previous seven months. Sixty three. 604 00:40:14,880 --> 00:40:19,239 Figure five increase in search volume in January twenty fifteen 605 00:40:19,519 --> 00:40:22,719 for the US and the UK relative to the previous 606 00:40:22,760 --> 00:40:27,039 seven months for the key phrase Virginia Roberts and Goalan Maxwell. 607 00:40:27,679 --> 00:40:31,760 Summary sixty four. The statements made against Miss Roberts have 608 00:40:31,880 --> 00:40:35,199 been disseminated to at least one hundred and fifteen online 609 00:40:35,239 --> 00:40:38,360 media or other sites in one hundred and seventy eight 610 00:40:38,400 --> 00:40:42,519 separate stories or articles with a combined sixty six million, 611 00:40:42,760 --> 00:40:45,440 nine hundred and nine thousand, nine hundred and sixty five 612 00:40:45,719 --> 00:40:50,440 individual unique visitors from January second, twenty fifteen to the 613 00:40:50,519 --> 00:40:54,000 date that I filed this report inclusive more likely than not, 614 00:40:54,400 --> 00:40:58,119 this is a conservative estimate. Sixty five. Right to amend. 615 00:40:58,639 --> 00:41:02,559 Although I have had access to materials publicly available pertaining 616 00:41:02,559 --> 00:41:05,199 to claims in this dispute. I have not been able 617 00:41:05,239 --> 00:41:08,239 to review all the material by the deadline for completion 618 00:41:08,400 --> 00:41:11,559 of this report. I reserve the right to review and 619 00:41:11,679 --> 00:41:15,280 rely on any such material, including at the time of trial. 620 00:41:15,599 --> 00:41:18,639 I also reserve the right to issue a supplemental or 621 00:41:18,639 --> 00:41:22,719 an amended report if my review of such material results 622 00:41:22,719 --> 00:41:27,239 in any significant change or addition to my opinion. Respectfully 623 00:41:27,280 --> 00:41:32,440 submitted Doctor Bernard Jay Jansen, dated September ninth, twenty sixteen. 624 00:41:32,920 --> 00:41:35,000 All right, folks, that's going to do it for this one. 625 00:41:35,360 --> 00:41:38,199 All of the information that goes with this episode can 626 00:41:38,239 --> 00:41:40,440 be found in the description box.