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Case 18-2868, Document 283, 08/09/2019, 2628241, Page494 of 883 Slave, Virginia Roberts Lies, Virginia Giuffre Lies, Virginia Roberts Giuffre Lies, Virginia Roberts Untrue, Virginia Giuffre Untrue, Virginia Roberts Giuffre Untrue, Virginia Roberts Liar, Virginia Giuffre Liar, Virginia Roberts Giuffre Liar, Virginia Roberts Ross Gow, Virginia Giuffre Ross Gow, Virginia Roberts Giuffre Ross Gow, Virginia Roberts Ross dishonest, Virginia Giuffre Ross dishonest, Virginia Roberts Giuffre dishonest, victims refuse silence sex slave 32. However, nowhere in his report does Mr. Anderson explain why these 26 search terms are important, beyond the fact that, he claims incorrectly, searching the major search engines with these phrases results in links to Web pages that contain allegedly defamatory material. However, this is true of literally thousands of different search phrases it’s a simple task to create search terms to match particular pages _ but he never explains why these particular 26 phrases are relevant. 33. As I explain below in detail, Mr. Anderson’s testimony is unreliable because it is not based on sufficient facts or data, nor is it the product of reliable principles and methods. Rather, it is seriously flawed in a number of ways. 1. Mr. Anderson’s Choice of Search Terms Is Arbitrary 34. Mr. Anderson, in his report, provides a list of 26 search terms (Page 7) that appear to have been chosen in an arbitrary manner; furthermore, Mr. Anderson does not explain how these search terms are relevant to this case. Most of the examples are rarely if ever searched upon, and return few, if any, relevant results (that is, links to pages that discuss or recount Defendant’s alleged defamatory statements). 35. Search terms are only relevant to this case if a searcher, wishing to find information about Plaintiff, would type the terms into a search engine. Mr. Anderson does not explain why such a person would type, for instance, the term victims refuse silence sex slave; in fact there seems no reason to believe that such a person would use this term. Why would someone wanting to research information about Plaintiff use the term virginia roberts lies, or virginia roberts ross gow? Mr. Anderson does not suggest any reason that somebody should use such terms. Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation or the fact that Defendant had denied Plaintiff's original allegations. These are not terms likely to be used by Mr. Anderson’s “casual searcher” (“I conducted an investigation to determine the Expert Report of Peter Kent Virginia L. Giuffre v. Ghislaine Maxwell 10