Earned Media Valuation & Communications Measurement · Available for Deposition and Trial Testimony
When litigation turns on the question of what media coverage is worth, courts and counsel need an expert whose credentials are unimpeachable and whose methodology will withstand cross-examination. Katie Delahaye Paine has spent four decades defining the standards by which earned media is measured — and can explain those standards clearly to judges, juries, and opposing counsel.
10 Ways Katie Can Help Your Case
- Assessing the validity of opposing expert media valuations Reviewing methodology, impression counts, CPM benchmarks, and data sourcing for accuracy and compliance with published industry standards.
- Calculating defensible earned media value Applying outlet-specific CPMs, filtering for bot traffic, geographic relevance, and audience quality to produce a rigorous, auditable valuation.
- Quantifying reputational damage from defamation or tortious interference Establishing pre-incident baselines and measuring the change in media quality, sentiment, share of voice, and brand prominence.
- Explaining industry standards to non-expert audiences Translating the Barcelona Principles, AMEC Integrated Evaluation Framework, and MRC standards into plain language for courts and juries.
- Attribution analysis — who benefited from the coverage Distinguishing the media value attributable to each party in multi-stakeholder disputes, including sponsors, talent, agencies, and brands.
- Critiquing AVE and CPM methodologies Assessing whether valuation methods conform to or deviate from published industry standards and accepted practice.
- Valuing PR agency campaign results in contract or fee disputes Assessing the quality and business impact of earned media generated under a PR retainer or project agreement.
- Analyzing social and digital media valuation claims Evaluating earned coverage value across digital platforms with full awareness of bot traffic, invalid clicks, and UVM overstatement.
- Non-testifying consulting on opposing expert methods Supporting counsel in understanding weaknesses in an opposing media valuation expert’s methodology and preparing for cross-examination.
- Preparing clear, Daubert-ready expert reports Producing thorough written opinions grounded in documented industry methodology, structured to withstand challenge.
About the Expert
Katie Delahaye Paine is the founder and CEO of Paine Publishing and one of the world’s foremost authorities on communications measurement and earned media valuation. She has been measuring the value of media for four decades, founding three measurement companies — The Delahaye Group (acquired 1999), KDPaine & Partners (acquired 2013), and Paine Publishing.
She is the author of three books on PR measurement: Measure What Matters (Wiley, 2011), Measuring the Networked Nonprofit (Wiley, 2013), and Measuring Public Relationships (2007). She is a founding member of the Institute for Public Relations Measurement Commission and a co-creator of the Barcelona Principles — the first internationally recognized standards for public relations measurement, now in their fourth version.
As an expert witness, Katie brings the same precision and clarity to legal proceedings that she brings to boardrooms — translating complex measurement methodology into findings that judges, juries, and opposing counsel can understand and interrogate.
Areas of Expertise & Types of Cases Served
Katie’s expertise spans the full spectrum of earned media — traditional print and broadcast, online news, digital platforms, social media, and influencer content. She is available for both plaintiff and defense engagements.
Valuation Topics
- Earned Media Value (EMV) methodology assessment and critique
- Advertising Value Equivalency (AVE) — limitations, and industry rejection
- CPM benchmarking: outlet-specific vs. flat-rate methodologies
- Impression counting accuracy: UVM overstatement, bot traffic, geographic waste
- Attribution of media value among multiple parties and beneficiaries
- Social and digital media valuation: platforms, influencers, and data quality issues
- Barcelona Principles and AMEC Integrated Evaluation Framework compliance
- MRC accreditation standards for impression measurement
Types of Cases
>Industries & Sectors
Katie brings deep familiarity with the media landscapes, earned coverage patterns, and measurement benchmarks specific to each of the following sectors — an essential foundation for credible industry-specific valuations.
On Daubert admissibility: Katie’s valuations are grounded in published, peer-accepted industry standards — the Barcelona Principles (AMEC, 2010–2025), the AMEC Integrated Evaluation Framework, PAVE Guidelines, and MRC measurement standards. This documented methodological foundation provides the Daubert compliance that courts require.
A methodology that cannot be traced to published standards, that applies a flat CPM without outlet-level justification, or that reports impression counts without filtering for bot traffic, geographic relevance, or audience quality is unlikely to survive rigorous cross-examination. Katie’s reports are built to withstand it.
How It Works
Frequently Asked Questions from Counsel
What makes an earned media valuation admissible under Daubert?
Admissibility requires that the methodology be grounded in sufficient facts or data, based on reliable principles and methods, and reliably applied to the facts of the case. Katie’s valuations are anchored in the Barcelona Principles, the AMEC Integrated Evaluation Framework, and MRC standards — all published, widely-adopted industry standards that provide the peer acceptance courts look for.
What is the difference between earned media value and advertising value equivalency?
Advertising Value Equivalency (AVE) equates editorial coverage to the cost of purchasing equivalent ad space — a methodology formally rejected by AMEC, CIPR, and PRSA since 2010. Earned media value, properly measured, incorporates quality factors including message accuracy, outlet authority, sentiment, audience relevance, and geographic reach. Katie can explain these distinctions clearly for a court and identify where an opposing expert’s methodology violates published standards.
Can Katie quantify reputational damage in a defamation case?
Yes. By establishing a pre-incident baseline of media quality, sentiment, and share of voice, then measuring the change following the defamatory event, Katie can produce a defensible quantification of media-based reputational harm supporting damages calculations in defamation, trade libel, and tortious interference matters.
Does Katie cover digital and social media, or only traditional press?
Both. Katie’s expertise spans the full spectrum: traditional print and broadcast, online news, social platforms, and influencer content. She is acutely aware of data quality issues in digital measurement — bot traffic, UVM overstatement, invalid clicks — that routinely inflate claimed values and are central to many media valuation disputes.
Does Katie take plaintiff and defense engagements?
Yes. Katie accepts engagements for both sides and is available as a testifying expert or as a non-testifying consulting expert to support counsel in evaluating an opposing expert’s methodology or preparing cross-examination.
How are fees structured?
Expert witness fees are billed hourly for case review, report preparation, deposition, and testimony. A retainer is typically required at engagement. Contact Katie directly for current rate information.
Contact Katie to Discuss Your Matter
Available for confidential preliminary consultations with counsel. Please reach out directly to discuss whether her expertise fits your case.
For our downloadable credential click here