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Case 18-2868, Document 283, 08/09/2019, 2628241, Page495 of 883 106. However, this 3-step process (create pages, place them on Web sites, create links to the pages) is not very efficient, regardless of the fact that it is common in the ORM business. One should keep in mind that the primary goal of any business is maximizing profits, not efficiency. The 3-step process may be inefficient, but it has the advantage of increasing the income of ORM firms; rather than merely creating links, they can also charge for the creation and placement of Web pages. There is, however, an alternative strategy that some ORM firms in fact do use, as I describe later in this report. 2. The Problems With Mr. Anderson’s Strategy 107. Mr. Anderson’s strategy is unnecessarily expensive and complicated, for a number of reasons: e Mr. Anderson exaggerates the number of Web pages (780) that must be pushed down in the search results e Placing new Web pages on quality Web sites will be very difficult, and unnecessary e Pushing the new Web pages up in the search results will be very difficult a) Mr. Anderson Exaggerates the Number of Web Pages (780) That Must Be Pushed Down In The Search Results 108. Mr. Anderson has stated that 7830 Web pages must be pushed down in the search results; he takes his 26 search phrases, and multiplies by 30 results (in theory 10 results per search-result page, over three pages, in order to push the “offending” pages down to the fourth page, though in some cases, in particular on Google, there may actually be fewer results on the first page, perhaps 8 or 9.) This is wrong for various reasons. Most of the Search Terms Will be Used Infrequently If Ever 109. As noted earlier, most of Mr. Anderson’s 26 search terms are infrequently if ever employed by searchers. Why, for instance, would it be necessary to push down offending Web pages in the results that the search engines provide for the term victims refuse silence sex slave, when this term is likely never used (and furthermore, that the search results contain no Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell 33