Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
In this episode, we're diving right back into the court
documents and we're going to take a look at the
expert witness report of doctor Bernard Jay Jansen, who is
a professor at the College of Information of Sciences and
Technology at penn State University, regarding the case of Virginia
Roberts and Galaine Maxwell. Introduction. I have been retained by
the law firm of Farmer Jaffey, Weissing, Edwards, Fistos and
Layerman Pel to provide expert analysis and opinion on behalf
of Miss Virginia Roberts in Virginia Roberts Plaintiff versus Glaiine Maxwell, Defendant.
Two qualifications. I am a tenured full professor at the
College of Information Sciences and Technology at the Pennsylvania State University,
University Park, Pennsylvania, where I've been employed since two thousand
and one. I am the director of the Information and
Learning Laboratory at the College of Information Sciences and Technology
at penn State University. I am also a principal scientist
at the Cutter Computing Research Institute. I was a senior
fellow at the Pew Internet and American Life Project, which
is part of the Pew Research Center. From twenty ten
to twenty twelve, I was also a university expert at
the National Ground Intelligence Center from twenty eleven through twenty fourteen.
Prior to my employment at the Pennsylvania State University, I
was a lecturer in the Computer science program at the
University of Maryland Asian Division for one year. Before that,
I was an assistant professor and lecturer in the Department
of Electrical Engineering and Computer Science at the United States
Military Academy AKA West Point for three years. Number three.
In addition to my academic credentials, my professional experience includes
twenty years of practice in the US military, working primarily
in a variety of technology related leadership positions. Number four.
I have authored approximately two hundred and fifty academic publications
focusing on the areas of web data, digital analytics, web analytics,
web searching, web search engines, social media analytics, and related areas.
Approximately two hundred of my publications address aspects of search analytics,
web analytics, online advertising, search engines, or web searching. My
recent research work focuses on online news analytics, which is
the investigation of the online qualitative and quantitative attributes of
news stories, along with other digital content. I am also
the editor in chief of the academic journal Information Processing
and Management, and I was previously the editor in chief
for five years of the academic journal Internet Research. I
have authored, co authored, or co edited for books including
Web Search Public Searching of the Web two thousand and seven,
Understanding User Web Interactions via Web Analytics two thousand and nine,
and Understanding Sponsored Search twenty eleven. A copy of my
complete curriculum, which includes a list of all publications I
have authored in the past ten years, is attached as
Appendix A number five. My fields of professional expertise include
web analytics, search engines, web searching, social media, online advertising,
and related areas. In the course of my academic career,
I have worked with a variety of search engines and
information searching applications in order to understand user searching behavior
on the Web and in other environments. For example, as
part of my master's degree program in computer science, I
designed and coded a text based search engine. For my
doctorate program in computer science, I developed a program interface
for web search engines and implement entered it on the
gigabyte Search engine. In subsequent research, I have worked with
Microsoft Internet Information Services and Verity Commercial Searching Services six
concerning user searching behaviors on the web using web analytics.
I have worked directly with real user searching data from
several search engines, including AOL, Alta, Vista, Dogpile, Excite, and
MSN Live. I've also analyzed web data of visitor traffic
and other attributes from a variety of websites and social
media platforms. I have analyzed real user data from online
search marketing campaigns and user referral traffic to websites. I
have conduct research and teaching concerning aspects of websites and
social media platforms, including keyword advertising. I've developed web analytics
models and processes for analysis of business goals, and I
have used web analytic data and commercial tools and both
my research and my teaching, I've also conducted other research
on users searching and related online behaviors. I have advised
governmental agencies and companies in consulting and expert witnessing matters.
A list of cases in which I have testified as
an expert witness in a deposition or trial in the
past four years is attached as the appendix be I
am being compensated for my work on this case at
the rate of three hundred dollars per hour. Number three
Assignment and materials considered Number seven. In providing my expert opinion,
I have been asked to respond to the following question
Number eight, what is the dissemination of the statements from
Miss Maxwell referring to Miss roberts declaration as untrue and
lies from when the statements were made on the second
of January twenty fifteen to the date that I filed
this report Number nine. For brevity, I refer to references
to the statement denoting Miss roberts declarations as untrue and lies.
Any related accounts referring to those original statements or similar
statements from Miss Maxwell or representatives referring to Miss Roberts
as the statements made against Miss Roberts, the statements from
Miss Maxwell's message, or the message from mister Gal Number ten.
My analysis is based on my experience, training, knowledge, and
education and is formed through the application of that experience, training, knowledge,
and education in the principles of web data collection, web analytics,
web search search engines, websites, web traffic analysis, and related
market analysis. Number eleven. The materials that I considered in
preparing this report are listed in Appendix see the Summary
of opinions twelve. Based on my research and analysis in
connection with this assignment, which is described in more detail
in the body of this report, along with my own experience, training, knowledge,
and education stated below, I have reached the following opinion
number thirteen. Statements made against Miss Roberts have been disseminated
to at least one hundred and fifteen online media or
other sites in one hundred and seventy eight separate stories
or articles with a combined sixty six million, nine hundred
and nine thousand, nine hundred and sixty five potential unique
visitors since January two, twenty fifteen, to the date that
I filed this report inclusive fourteen. This is a conservative estimate,
and it is more likely than not the statements made
by Miss Maxwell against Miss Roberts have received a wider
dissemination due to the factors such as a I used
a set of online websites to measure dissemination, and it's
reasonable that I have not located all references to the
statements made against Miss Roberts on every website by the
time of the submission of this report. B. I examined
only online sources referencing the statement made against Miss Roberts,
and not print or broadcast media dissemination of the statements
made against Miss Roberts. See. I have not attempted to
measure face to face dissemination of articles containing the statements
against Miss Roberts. D. I do not have access to
certain online sources where articles containing the statements against Miss
Roberts may have been disseminated. E. There are possibly sites
that have hosted the statements made against Miss Roberts that
I cannot locate, or where the statements have been removed.
F There are sites that hosted the articles containing the
statements made against Miss Roberts where the visitor data is
not accessible, or where I could not confirm the number
of visitors. G. I did not consider the dissemination via
social media platforms of articles containing the statements made against
Miss Roberts. H. Many sites published multiple articles on multiple
days that contained or referenced the statements made against Miss Roberts.
How However, I did not include these multiple publication dates
in calculating unique daily visitors. I. I did not include
unique daily visitors to articles that link from the article
till one or more of the articles containing the statements
made against Miss Roberts Jay. Finally, I did not include
the accounts of those who may have been searching and
seen the statements made against Miss Roberts in the search
results listing Part five. Background web analytics for traffic analysis fifteen.
In the course of forming this opinion, I implemented numerous web
analytics and related techniques commonly used in the industry. In
order to more clearly discuss these techniques, I define the
following terms. Direct traffic visitors to a website that come
from entering a website link into a browser location eg.
Not coming from a link or another website. Dissemination, the
act of spreading, or the circulation of information or articles
domain a specific Internet website that are administered as a
unit and defined by an Internet Protocol address. Reach the
percentage or number of people who visit a website out
of the total targeted population. Referral traffic visitors to a
site that come from websites other than search engines, repeat
visits visitor traffic to a website in a given period
that just includes multiple visits from the same set of
IP addresses IE IP addresses with more than one visit
provides account of the people who have visited a site
more than once in a given period. An individual is
usually defined by a combination of IP addresses and browser
within a given period, but can also be defined by
more sophisticated methods. Search engine a program and associated hardware
and processes that allows people to find information on the web,
typically via the submission of queries consisting of terms search
traffic visitors to a site that come from search engines
rather than from other websites, or via direct navigation search
a submission of a query to a search engine, usually
in the form of terms forming a query. Share sharing
of an article or a web page, typically via some
social media platform social media content that is shared via
social media networking websites. Unique visits visitor traffic to a
website within a given period that includes only the first
visit IE. Subsequent visits are ignored, which excludes repeat visits,
provides account of the individuals who have visited in a
site in a given period. Unique daily visitors visitor traffic
to a website who visits a site at least once
in a given twenty four hour period. Each visitor to
the site is counted once during the reporting period, which
means it exc fludes repeat visits. Provides account of the
individuals who have visited a site on a given day.
Visits account of all the traffic to a website in
a given period, including both unique and repeat visits. Web
analytics the measurement, collection, analysis, and reporting of web data.
All right, folks, we're going to wrap up right there,
and in the next episode, we're going to pick up
where we left off. All of the information that goes
with this episode can be found in the description box.
What's up, everyone, and welcome back to the Epstein Chronicles.
In this episode, we're going to dive right back into
that expert witness testimony that we were talking about in
the last episode, So let's get back to it. Part six.
Methodology sixteen. I was asked to determine the dissemination of
articles containing the statements made against Miss Roberts seventeen. Informing
my opinion, I utilized accepted web analytics and related methodologies
in developing my assessment eighteen. To that end, I employed
various publicly available online analytics services as well as some
subscription based services. In conducting my research including Alexa, an
online service that provides web traffic data and analysis. Compete
an online service that provides web traffic data and analysis.
Google Keyword Tool an online service that provides the number
of searches for a given set of keywords in a
given month on the Google search engine. Google Trends an
online service that shows how often a particular term is
relatively searched on the Google Search Engine in a given period.
Similar Web an online service that provides web traffic data
and analysis. Spyfu an online service providing search data and analytics,
including for both paid IE advertisements and organic IE natural
algorithmic channels. W three snoop an online service that provides
web traffic data and analysis. Nineteen. These tools offer a
variety of data and analysis services, and they are frequently
utilized by industry professionals in the search engine optimization, web analytics,
and search engine marketing fields for market customer and competitive analysis. Furthermore,
where possible, I did my own assessments as outlined below.
In order to validate the data and analysis results. Number twenty,
I utilize search engines, primarily Google, ending to assess the
dissemination of articles containing the statements made against Miss Roberts
twenty one. Whenever possible, I use multiple data sources, which
is a data verification technique known as triangulation, where one
uses multiple and disparate sources of analysis and then compare
the results from the separate analysis. If the results are similar,
it reinforces the conclusion that the overall data analysis is valid.
Number twenty two. In all of my assessments, I have
used the most conservative numbers, meaning that I use the
smallest value in arriving at the dissemination of articles containing
the statements made against Miss Roberts. If I had employed
this conservative estimate, the number of potential dissemination of articles
containing the statements made against Miss Roberts would be one
hundred and two million, seven hundred and forty thousand, eight
hundred and sixteen daily unique visitors. Number twenty four. My
analysis is based on my experience, training, knowledge, and education
is formed through the application of that experience, training, knowledge,
and education in the principles of web data collection, web analytics,
web search search engines, websites, and related areas Number seven.
Dissemination of the statements made against Miss Robbers twenty five.
My opinion is that the articles containing the statements made
against Miss Roberts have been disseminated to at least one
hundred and fifteen online media and other sites in one
hundred and seventy eight separate stories or articles with a
combine sixty six million, nine hundred and nine thousand, nine
hundred and sixty five unique daily visitors twenty six. This
is a conservative estimate, and it's more likely than not
the statements have received wider dissemination due to the factors
such as A. I used a set of online websites
one hundred and fifteen to calculate the dissemination of the articles,
and it's reasonable that I have not located all references
to the statements made against Miss Roberts by the time
of the submission of this report, so there may be
more sites with articles containing the statements made against Miss
Roberts that are not included in my calculations. B. My
focus of analysis was the online dissemination of the statements
made against Miss Roberts. Therefore I examined only online sources
and not dissemination of the statements made against Miss Roberts
via print or broadcast media. It is reasonable to assume
that the statements made against Miss Roberts were disseminated via
these other channels. See. I have not attempted to measure
face to face dissemination of the statements made against Miss Roberts. Therefore,
these sources of dissemination are not included in the account
of Daily Unique visitors. D. I did not have access
to certain online sources where the statements against Miss Roberts
may have been disseminated e g. Email messages, social media messages,
articles behind firewalls, et cetera. Therefore, these sources are not
included in account of Daily Unique visitors. E. There may
be sites that hosted articles containing the statements made against
Miss Roberts, where the articles have been removed. Therefore, I
did not include these sites in my calculation of the
unique daily visitors. F. There are sites where the visitor
data is not accessible or where I could not reasonably
check the number of visitors. In these cases, even though
I had confirmed the site had posted one or more
articles containing statements made against Miss Roberts, I did not
include these sites in my calculation of the unique daily visitors. G.
I did not consider the dissemination via social media platforms
of articles containing the statements against Miss Roberts. H Many
sites publish multiple articles on multiple days that contain or
reference the statements made against Miss Roberts. However, I did
not use these multiple articles from the same site with
different publication dates in my calculations in determining the number
of daily unique visitors who have been exposed to the
articles containing the statements made against Miss Roberts. I I
did not include articles that link to one or more
of the articles containing the statements made against Miss Roberts.
Unless the article directly referenced the statements made against Miss Roberts,
I did not include it in my analysis. Jay. Finally,
I did not include people who may have been searching
and may have seen the statements made against Miss Roberts
in the search results without needing to visit the actual
articles posted on the websites. Number eight Methodology to determine
the dissemination of the statements made against Miss Roberts twenty seven.
I have been informed that the statements made against Miss
Roberts were originally contained in an email message from Ross
Gau of Acuity Reputation, acting on behalf of Miss Maxwell
that was sent on January two, twenty fifteen, at eight
thirty eight pm to based on the email addresses people
at The Mail Online, The Independent, The Mirror, The Times
and the BBC. The email message from mister gu contained
the statements made against Miss Roberts. A scre greenshot of
the email message is shown in Figure one twenty eight.
Figure one email message from Roscale containing the statements made
against Miss Roberts thirty Additionally, on January eighth, twenty fifteen,
agents reportedly acting on behalf of Miss Maxwell made statements
that the allegations against her were a web of lies
and deceit, which are similar to the statements made against
Miss Roberts in the message from mister Gal thirty one. Similarly,
on February first, twenty fifteen, agents reportedly acting on behalf
of Miss Maxwell made statements that the allegations against her
were a web of lies and deceit, which are similar
to the statements made against Miss Roberts in the message
from mister Gal thirty one. Similarly, on February first, twenty fifteen,
like statements were quoted as these allegations are untrue and defamatory,
which are similar to the statements made against Miss Roberts
in the metassage from mister Gal thirty two based on
my investigation and research. News stories, articles and postings containing
direct reference to or quotes from the statements made against
Miss Roberts appeared the same day, January two, twenty fifteen
as the email from mister Gal, with several news organizations
and other sites publishing other articles containing direct reference to
or quotes from the statements made against Miss Roberts in
the immediate following days. News articles containing direct reference to
or quotes of the statements made against Miss Roberts have
continued to appear in news articles and other postings nearly
up to the date that I submitted this report Number
thirty three. A timeline of events relating to the dissemination
of the statements made against Miss Roberts is shown in Fig.
Two thirty four. Fig. Two Timeline of events relating to
the dissemination of the statements made against Miss Roberts from
Jijanuary second, twenty fifteen onwards. Number thirty five concerning the
procedure employed and determining the dissemination of the statements made
against Miss Roberts. Nearly every major news site that I investigated,
along with other specific news sites in the United States
the United Kingdom, Canada and Australia, as well as other countries,
have carried some aspects of the overall story related to
Miss Roberts and Dora Maxwell or other parties that are
involved thirty six. In fact, there are tens of thousands
of news articles and postings concerning the general story from
news outlets worldwide, with combined potential viewership in the multimillions
as searches on the major search engines such as Google
and Bing's show thirty seven. However, I was not interested
in news articles that just discussed the story in general
or other aspects of the story. Also, I was not
interested in those articles where Miss Maxwell or those acting
on her behalf such as mister Gall would just generally
deny the allegations in the complaint. I was specifically interested
in only those articles that reference directly or quoted the
statements made against Miss Roberts in the January second, twenty
fifteen email message from mister Goll to Miss Maxwell's subsequent
confirmation of the statements or similar statements as those in
the message from mister Goal. Naturally, this narrow focus is
a smaller subset of news articles than are the articles
addressing the overall story number thirty eight. To isolate these
articles of interest, I generated a series of ten queries
that specifically targeted news articles from the case that address
the statements made against Miss Maxwell E. G. Glenn Maxwell's
Obvious Lies. To retrieve a set of articles that directly
related to the statements made against Miss Roberts, I employed
a modified snowball technique, starting with one seed query, adding
and modifying terms until I was not receiving new results.
I also located some articles via navigating from the set
of retrieved articles thirty nine. I set the search rage
down from January second, twenty fifteen onward, so articles prior
to that date were not included in the search results.
For each article used in my analysis, I also verified
the date that the article was published to ensure it
was published on or after January second, twenty fifteen, and
that the articles directly referenced in some way the statements
made against Miss Roberts forty. An example of search engine
results in response to one of those queries is shown
in Fig. Three forty one. Figure three Google new search
results for the search Glenn Maxwell's Obvious Lies, with the
date delimiter beginning on January second, twenty fifteen. Forty two.
I then personally verified that each article by reviewing each
article used in my analysis directly referenced in some way
the state it's made against Miss Roberts. Forty three, So
articles relating to the overall story that did not mention
Miss Maxwell's statements made against Miss Roberts were not included
in the analysis. Articles relating to the overall story that
referred to Miss Maxwell simply denying the charges were not included.
Forty four. I also personally performed a site search of
the top fifteen online media sites worldwide of articles related
to the case, and I reviewed the results to identify
if any of these articles referred to the statements against
Miss Roberts. I also did the same for many countries
specific news sites in the United States, United Kingdom, Canada,
and Australia. Forty five. In the end, I had a
set of one hundred and seventy eight online news and
other articles from January two, twenty fifteen, to the date
that I filed the report that specifically referenced the statements
made against Miss Roberts. To conduct my analysis, as outlined below,
each of these one hundred and seventy eight online articles
was posted online. The one hundred and seventy eight online
articles were distributed among one hundred and fifteen unique domain
websites IE. Some websites posted multiple articles that contained the
statements made against Miss Roberts forty seven. As seen from
the list of domains that have published articles or stories
containing references to the statement made against Miss Roberts, many
of these domains are those of major news organizations or sources,
including AOL News, BBC, Huvington Boast, International Business Time, Irish Times,
MSN News, National Inquirer, New York Daily News, New Zealand Herald,
Page six, Radar Online, Reuters, The Daily Beast, The Daily Mail,
The Express, The Guardian, The Mirror, The Sun, The Telegraph,
Yahoo News, et cetera. Forty eight. I then used a
variety of web analytics, traffic services, and other sources to
get the unique daily visitor traffic for each of these domains.
I use multiple services when available to verify the unique
daily visitor traffic for each of these domains, as the
traffic services may use different techniques to arrive at their
traffic numbers. Forty nine In some cases, conflicting unique daily
visitor traffic numbers. I utilize the most conservative ie smallest
number fifty. In cases where I determined I couldnot get
unique daily visitor traffic numbers or the unique daily visitor
traffic was not reliable in my opinion, I did not
include the unique daily visitor traffic numbers for that domain
in the numbers. This usually occurred for the sites with
a smaller number of daily visitors or sites with an
extremely large number of daily visitors. Fifty one Unique daily
visitors measures as an industry standard web analytic metric for
measuring people that visit a website in a given period,
such as a week, a month, as there are normal
daily fluctuations. Fifty two. Table one shows the unique visitors
traffic for the listed domains that posted articles or stories
referencing the statements made against Miss Roberts, and the associated
unique daily visitor traffic for each of those domains, along
with a number of articles containing the statements made against
Miss Roberts posted on that site. All right, folks, we're
gonna wrap up this episode here and in the next
episode we're gonna pick up where we left off. All
of the information that goes with this episode can be
found in the description box. What's up, everyone, and welcome
back to the Epstein Chronicles. In this episode, we're diving
right back into the expert Witness Report of Bernard Jay
Janssen Number fifty three. Table one domains that published articles
or stories containing the statements made against Miss Roberts, with
the domain's number of unique daily visitors and the number
of articles containing the statements made against Miss Roberts published
on that domain from January two, twenty fifteen, to the
date that I filed this report fifty four. I used
each domain's unique daily visitor account to calculate the dissemination
of the articles containing the statements against Miss Roberts to
various websites and potentially visitors to that site, i e.
As visitors to the news sites. These individuals could have
been exposed to the articles containing the statements made against
Miss Roberts using the unique daily visitor number only once
for each domain, regardless whether that domain published more than
one article referring to the statements made against Miss Roberts
Part eleven, Number fifty five. Based on my analysis as
outlined above, my opinion is that the statements against Miss
Roberts have been disseminated to at least one hundred and
fifteen online media and other sites one hundred in seventy
eight stories or articles with a combined sixty six million,
nine hundred and nine thousand, nine hundred and sixty five
more than sixty six million unique daily visitor traffic. Fifty six.
I note that for many of the one hundred and
seventy eight articles containing the statements made against Miss Roberts,
one could get the gist of the story of the
article directly from the article headline. I point this out
as it's well known that people skim online news sites,
so titles such as these would have substantial impact on
visitors to that site. Fifty seven. This is a conservative
estimate and more likely than not articles containing the statements
made against Miss Roberts have been disseminated to more individuals.
Ten why the estimate is low fifty eight. This sixty
six million, nine hundred and nine thousand, nine hundred and
sixty five individual unique daily traffic is a conservative estimate,
and it is more likely than not the statements have
received wider dissemination due to factors such as a. Although
I spend a considerable effort to locate published articles that
contain the statements made against Miss Roberts. It's reasonable to
assume that I have not located all such articles by
the time of the submission of this report, so there
are possibly more sites with articles containing the statements made
against Miss Roberts that are not included in my calculations,
which would increase the dissemination of the articles b. The
focus of my analysis was the dissemination of online articles
containing the statements made against Miss Roberts, and I examined
only online sources and not print broadcast media. Many of
the media outlets that I did identify have considerable print
distribution which are not included in my calculations, such as,
for example, the Sun print circulation one million, seven hundred
and forty one thousand, eight hundred and thirty eight, Daily
Mail print circulation one million, five hundred and sixty two thousand,
three hundred and sixty one, the Daily Telegraph print circulation
four hundred and seventy two thousand, nine hundred and thirty six,
The Times print circulation four hundred and two thousand, seven
hundred and fifty two, The Guardian print circulation one hundred
and sixty one thousand, one hundred and fifty two see
In my analysis, I did not attempt to measure face
to face dissemination that may have occurred after individuals may
have read articles containing the statements made against Miss Roberts,
which would increase the count D. Naturally, I cannot access
certain online sources where the statements made against Miss Roberts
may have been disseminated e. Gmail messages, social media messages,
articles behind firewalls, et cetera. Therefore, these numbers are not
included in my calculations. E. Also, there are possibly sites
that have hosted articles containing the statements against Miss Roberts,
where the articles have been removed. Therefore they are not
included in my calculations. F For sites where more than
one article containing the statements made against Miss Roberts are posted,
but where I could not locate or not determine reliable
daily unique visitor traffic, I have not included these sites
in my calculations. There are fifty nine of the one
hundred and fifteen fifty one point three percent, to be precise,
where I could not get or not get verifiable traffic data.
For example, the traffic numbers for the MSN News, Microsoft
and Yahoo news are not separated by news and other
services such as search, so I did not include these
in the number of people to which the articles containing
the statement made against were disseminated. G I did not
include the dissemination of articles containing the statements made against
Miss Roberts directly to social media platforms. However, many of
the articles containing the statements made against Miss Roberts include
counts of the number of times that individuals shared the
article to a social media network, as shown in Table two.
As shown in Table two, the articles containing the statements
made against Miss Roberts have been shared thirty three thousand,
seven hundred and fifty eight times, mostly on Facebook. Given
that the medium number of Facebook friends is two hundred,
this equates to a possible six million, seven hundred and
fifty one thousand, six hundred individuals, in addition to the
thirty three thousand, seven hundred and fifty eight individuals who
originally shared the articles, to which the articles containing the
statements made against Miss Roberts could have been disseminated, assuming
these individuals are all unique and have not already read
one of the articles. However, I did not include these
social media shares in my calculations. Since news articles viewing
follows a power law distribution, there is no direct linear
ratio of number of social media shares to readership. There
is published research that does report average views of an
article on a news website and also average social media
shares in direct calculation with the numbers from the article
twenty three article views per social media share. Using thirty
three thousand, seven hundred and fifty eight social media shares,
this would be seven hundred and seventy six thousand, four
hundred and thirty four article views. However, this ratio would
vary by website, number of daily unique visitors, types of
news articles, time of accumulating shares, and possibly other factors. Plus,
this number would not account for the people receiving the
social media share that viewed the title post and snippet
but did not click on the shared to view the
article on the website, thereby undercounting views of the articles. Also,
given the topical nature of the underlying news story, one
could expect lower social media sharing but higher article viewing,
as people will tend to read articles on such topics
privately but not share on social media, so I would
expect this social media number itself to be an undercount
h I did not include articles that link to one
of the articles containing statements made by Miss Roberts in
my calculations of dissemination. Unless the article directly mentioned the
statements made against Miss Roberts, I did not include that
article in my calculations. So unless the linking article actually mentioned, referenced,
or quoted the statements made against Miss Roberts, I did
not include it in my calculations. Many sites published multiple
articles on multiple days that quoted or referenced the statements
made against Miss Roberts. However, I did not use these
multiple publication dates from the same site in my calculations
of unique visitor traffic. If a domain published only one
article containing the statements against Miss Roberts, then I directly
used the unique daily visitor number. If a domain published
multiple articles concerning the statements against Miss Roberts, I did
not count the traffic for the subsequent articles containing the
statements made against Miss Roberts, even though research shows that
repeat traffic to websites is generally only about thirty percent,
meaning that thirty percent of the traffic would be unique. However,
I was not comfortable using this figure given the nature
of these sites, which might have higher repeat visitors day
to day. Therefore, I did not include the unique visitors
to multiple articles in my calculations. Finally, I did not
include the count of people who may have been searching
and may have seen the statements made against Miss Roberts
in the search results without needing to visit the actual articles,
as shown in Figure four. Fig four example of search
results with the statements made against Miss Roberts appearing in
the results snippets requiring no need to visit the articles themselves.
Accuracy of the traffic numbers, and additional verification fifty nine
concerning the accuracy of the analysis. The number of domains
where the statements made against Miss Roberts have been disseminated
is reliable as this is straightforward to verify, ie the
article is either posted on a site or it is not.
If anything, that is an undercount, as some domains, for example,
may have removed such articles, making them no longer available.
There are possibly articles containing the statements that I have
not been able to locate by the time that I
submit this report. Sixty concerning traffic numbers for domains. A
unique visitor is typically identified by an identifier stored in
a text file which is based on an individual computers browser.
Although more sophisticated methods are also being used. In locating
traffic numbers for the domains, I used multiple services when available,
and attempted to verify via other sources. In case with
varying traffic data, I utilize the most conservative IE's smallest
number available, sixty one. I also verified findings from my
my analysis via other methods and my own experience in training.
For example, there are periods of increased publishing of articles
containing the statements made against Miss Roberts and related stories.
One would expect increases in associated searching during these periods.
Using the Google keyword tool, which provides search volume for
search queries by month, I examined search volume for January
twenty fifteen to the date that I filed this report.
There was fifty four thousand, five hundred and eighteen percent
increase in search volume for the keywords Virginia Roberts and
Glenn Maxwell and January of twenty fifteen relative to the
prior seven months in the US, and forty four thousand,
eight hundred and twenty two percent increase for the United Kingdom.
In January twenty fifteen relative to the prior seven months.
This is in line with the increase in posting of
articles during the same month, so once he is the
expected increase in searching for key t terms based on
the increase of posting articles. Sixty two. Figure five shows
increase in searching volume in January twenty fifteen for the
US and UK relative to the previous seven months. Sixty three.
Figure five increase in search volume in January twenty fifteen
for the US and the UK relative to the previous
seven months for the key phrase Virginia Roberts and Goalan Maxwell.
Summary sixty four. The statements made against Miss Roberts have
been disseminated to at least one hundred and fifteen online
media or other sites in one hundred and seventy eight
separate stories or articles with a combined sixty six million,
nine hundred and nine thousand, nine hundred and sixty five
individual unique visitors from January second, twenty fifteen to the
date that I filed this report inclusive more likely than not,
this is a conservative estimate. Sixty five. Right to amend.
Although I have had access to materials publicly available pertaining
to claims in this dispute. I have not been able
to review all the material by the deadline for completion
of this report. I reserve the right to review and
rely on any such material, including at the time of trial.
I also reserve the right to issue a supplemental or
an amended report if my review of such material results
in any significant change or addition to my opinion. Respectfully
submitted Doctor Bernard Jay Jansen, dated September ninth, twenty sixteen.
All right, folks, that's going to do it for this one.
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