Over the span of the last decade technological advances have created new ways to test case strategies and develop jury profiles. One development, which has been hotly debated, surrounds the increasing use of online surveys as an alternative to traditional modes of jury research. In 2002, nearly $500 million was spent on online surveys. By 2009, that number exploded to $2 billion (AAPOR). The shift away from traditional telephone methodologies can be attributed, in part, to the low cost and high degree of flexibility that online survey research offers.