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Case 18-2868, Document 283, 08/09/2019, 2628241, Page422 of 883
47. As seen from the list of domains that have published articles or stories containing
references to the statement made against Ms. Giuffre, many of these domains are those of major
news organizations or sources, including AOL News, BBC, Huffington Post, International
Business Times, Irish Times, MSN News, National Enquirer, 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, etc.
48. 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 used multiple services when available to
verify the unique daily visitor traffic for each of these domains, as these traffic services may use
different techniques to arrive at their traffic numbers.
49. In cases of conflicting unique daily visitor traffic numbers, I utilized the most
conservative (i.e., smallest) number.
50. In cases where I determined I could not get unique daily visitor traffic numbers or
the unique daily visitor traffic were 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.
51. Unique daily visitors measure is an industry standard web analytics metric for
measuring people that visit a website in a given day, also known as unique audience’. It is
generally averaged out over multiple days with a given period, such as week or month, as there
are normal daily fluctuations.
52. Table | shows the unique daily visitor traffic for the listed domains that posted
articles or stories referencing the statements made against Ms. Giuffre and the associated unique
» http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf
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Extracted Information
Dates
Document Details
| Filename | DocumentCloud_Epstein_Docs_p01389.png |
| File Size | 276.5 KB |
| OCR Confidence | 95.7% |
| Has Readable Text | Yes |
| Text Length | 1,996 characters |
| Indexed | 2026-02-04 12:28:54.165722 |