I think Google bases a lot of its ranking on bounce rate, i.e. "how often people who searched this were happy with this result." I don't think you need that many hits to establish bounce rate for quite specific searches. Like, is 40 is enough? I can imagine so.
But if you filter for paid members, you've filtered for much smarter people (on average) picking the best results - and you've also filtered out a lot of the SEO people who are going to be trying to manipulate the bounce rate with proxies.
But if you filter for paid members, you've filtered for much smarter people (on average) picking the best results - and you've also filtered out a lot of the SEO people who are going to be trying to manipulate the bounce rate with proxies.