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Case 18-2868, Document 283, 08/09/2019, 2628241, Page405 of 883 advertising. I’ve developed web analytics models and processes for analysis of business goals, and I have used web analytics data and commercial tools in both my research and teaching. I’ve also conducted other research on user 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 in deposition or trial in the past four years is attached as Appendix B. I am being compensated for my work on this case at the rate of $300 per hour. Il. ASSIGNMENT AND MATERIALS CONSIDERED 7. In providing my expert opinion, I have been asked to respond to the following question: 8. What is the dissemination of the statements from Ms. Maxwell referring to Ms. Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2 January 2015 to the date that I filed this report? 9. For brevity, I refer to references to the statements denoting Ms. Giuffre’s declarations as “untrue” and “lies”, any related accounts referring to those original statements, or similar statements from Ms. Maxwell or her representatives referring to Ms. Giuffre as the statements made against Ms. Giuffre, the statements from Ms. Maxwell’s message, or the message from Mr. Gow’. 10. 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, web sites, web traffic analysis, and related market analysis. 11. The materials that I considered in preparing this report are listed in Appendix C. 1 See, para. 30 and 32, Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. 4