Just an FYI. I've been getting free papers, two days a week for several years, which doesn't come close to my definition of "intermittent" copies.
Your response seems to infer that the publishers self-report by filling out a form, and then are subject to be audited.
All said, I'm really not qualified to judge, so I'll trust the process is credible.
I know a lot more than when I first posted.
Thank you for taking the time.
That is true that publishers self report and then are audited, but intermittent copies are closely watched. Who knows? It is possible those copies are samples and are reported as unpaid hoping you will subscriber 7 days a week.