UNITED STATES DISTRICT COURT FOR THE ... - LCD Class Action

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Case3:07-md-01827-SI Document6141-11 Filed07/12/12 Page20 of 138 In Re TFT-<strong>LCD</strong> (Flat Panel) Antitrust Litigation PAID MEDIA NOTICE PROGRAM: PLACEMENT SUMMARY The following list provides a brief summary of KM’s recommended media placements in this case. More detailed information about each component and its applicability to the target audiences in this case appears in the Paid Media Placements section of this plan. PRINT PUBLICATIONS Consumer Magazines § Newsweek § People § Sports Illustrated § Time Newspaper Supplements § Parade § USA Weekend National Newspapers § New York Times (Sunday) § Wall Street Journal TELEVISION 30-second spots § Network Cable ONLINE MEDIA Internet Banner Ads § 24/7 Network § Facebook § Macworld § Microsoft Media Network § NetShelter Tech Network § PCMag.com § PCWorld § Quadrant One § Specific Media U.S. Territory Newspapers © 2011 KINSELLA MEDIA, LLC 11 § Agana Pacific News (Guam) § El Nuevo Dia (Puerto Rico) § El Vocero (Puerto Rico) § Primera Hora (Puerto Rico) § Saipan Tribune (Northern Mariana Islands) § Samoa News (American Samoa) § St. Croix Avis (St. Croix, U.S.V.I.) § St. John Trade Winds (St. John, U.S.V.I.) § St. Thomas News (St. Thomas, U.S.V.I.) § Virgin Islands Daily News (St. Thomas, U.S.V.I.) Keyword Sponsorships § Google § Yahoo! § Bing
Case3:07-md-01827-SI Document6141-11 Filed07/12/12 Page21 of 138 In Re TFT-<strong>LCD</strong> (Flat Panel) Antitrust Litigation PAID MEDIA NOTICE PROGRAM: METHODOLOGY Notice programs directed to unidentified class members need to: (1) identify the demographics of class members and establish a target audience, (2) outline the methodology for selecting the media and other program elements and how they relate to product usage or exposure, and (3) provide results that quantify for the court the adequacy of the notice based upon recognized tools of media measurement. In the wake of the Supreme Court’s decisions in Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993) and Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999), the reliability of a notice expert’s testimony should be tested against the standards developed within the media industry for determining to what degree and at what frequency a target audience has been reached. In assessing the expert’s reliability, the court must determine whether the testifying expert “employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field.” Kumho, 526 U.S. at 152. That showing would likely require evidence that the expert’s data and methodology are similar to that used by professionals in the relevant field. In keeping with the Daubert and Kumho rulings, KM employs methodology and measurement tools used in the media planning and advertising industry to design a paid media program and to measure the adequacy of that program to reach a particular audience. Choosing a target audience that encompasses the demographic characteristics of class members is the first step in designing the paid media program. KM then chooses media vehicles based on their ability to provide effective and cost-efficient penetration of the target audience. Finally, KM measures selected vehicles against the target audience to quantify the reach of the media program and the frequency of exposure to the media vehicles. Reach and frequency estimates are two of the primary measurements used to quantify the media penetration of a target audience. ➢ Reach is the estimated percentage of a target audience that is exposed one or more times through a specific media vehicle or combination of media vehicles within a given period. ➢ Frequency is the estimated average number of opportunities an audience member has to see the notice. © 2011 KINSELLA MEDIA, LLC 12
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