[fooey]

The criteria is a "one or more of the following" not a combination of them all

So if you make more than $25 million, OR your have more than 50k users or devices, OR you make more than 50% of your money selling data

[AnthonyMouse]

Seems like the second one is the real problem. "50K users or devices" is less than 0.02% market share, even if you have only US customers, and for businesses with margins in the $1/user/year range it doesn't even cover one full time employee.

You can end up with that many users on a side project all of a sudden if it gets posted to the front page of a site like this one.

[coldacid]

And it doesn't even have to be users in the signed-up sense if you simply have access logging turned on for your web server; 50k unique IPs would be enough.

[pkaye]

50K California customers.

[AnthonyMouse]

So less than 0.13% market share then.

Assuming you have any way to reliably identify which state your users are in -- which means we're back to "privacy regulations" encouraging companies to collect more data on their users.