Costar Group Inc. v. Loopnet, Inc., 164 F.Supp.2d 688 (D. Md., 2001) touched on this.
The court distinguishes Playboy Ent. v. Russ Hardenburgh, Inc., 982 F.Supp. 503 (N.D.Oh.1997) which held that "contributory liability could attach where infringing performances enhance the attractiveness of the venue to potential customers." (internal quotes omitted) This sounds like your concern. The Costar court stated explicitly that merely adding value does not constitute direct benefit.
In Costar the court found that
Whereas in Playboy and Fonovisa, the finding of added value to the
defendant was evidence that the defendant induced the infringement,
for the purposes of the DMCA, the financial benefit must be "directly
attributable to the infringing activity." 17 U.S.C. § 512(c)(1)(B)
(1998). CoStar might make an argument that the indirect type of
benefit cited in Hardenburgh is also present here. However, such a
benefit does not fit within the plain language of the statute.
Accordingly, § 512(c)(1)(B) does not present a barrier to LoopNet
remaining in the safe harbor.
You could also take a look at Columbia Pictures Indus., Inc. v. Fung, 710 F.3d 1020 (9th Cir., 2013)
the relevant inquiry is “ ‘whether the infringing activity constitutes
a draw for subscribers, not just an added benefit.’
That case cites Ellison v. Robertson, 357 F.3d 1072 (9th Cir., 2004)
Ellison ultimately concluded that the financial benefit standard was
not met, because there was inadequate proof that “customers either
subscribed because of the available infringing material or cancelled
subscriptions because it was no longer available.”
But back to Fung, check this out (I quote this in its entirety because it's not that long and it should lead you to your own conclusion):
Against this background, we note that we have never specified what
constitutes a “financial benefit directly attributable to the
infringing activity,” 17 U.S.C. § 512(c)(1)(B) (emphasis added),
where, as here, the service provider's revenue is derived from
advertising, and not from users. We do so now.
Here, the record shows that Fung generated revenue by selling advertising space on his websites. The advertising revenue depended on
the number of users who viewed and then clicked on the advertisements.
Fung marketed advertising to one advertiser by pointing to the “TV and
movies ... at the top of the most frequently searched by our viewers,”
and provided another with a list of typical user search queries,
including popular movies and television shows. In addition, there was
a vast amount of infringing material on his websites—whether 90–96% or
somewhat less—supporting an inference that Fung's revenue stream is
predicated on the broad availability of infringing materials for his
users, thereby attracting advertisers. And, as we have seen, Fung
actively induced infringing activity on his sites.
Under these circumstances, we hold the connection between the infringing activity and Fung's income stream derived from advertising
is sufficiently direct to meet the direct “financial benefit” prong of
§ 512(c)(1)(B). Fung promoted advertising by pointing to infringing
activity; obtained advertising revenue that depended on the number of
visitors to his sites; attracted primarily visitors who were seeking
to engage in infringing activity, as that is mostly what occurred on
his sites; and encouraged that infringing activity. Given this
confluence of circumstances, Fung's revenue stream was tied directly
to the infringing activity involving his websites, both as to his
ability to attract advertisers and as to the amount of revenue he
Edit to add:
There is also some legislative history that some courts point to at H.R.Rep. No. 105-551, Part 2. (I include the link to the closest thing I could find.) This language shows its age! I think the only thing that speaks to your issue is the last sentence (bc it's not you).
In determining whether the financial benefit criterion is satisfied,
courts should take a common-sense, fact-based approach, not a
formalistic one. In general, a service provider conducting a
legitimate business would not be considered to receive a ‘financial
benefit directly attributable to the infringing activity' where the
infringer makes the same kind of payment as non-infringing users of
the provider's service. Thus, receiving a one-time set-up fee and
flat, periodic payments for service from a person engaging in
infringing activities would not constitute receiving a ‘financial
benefit directly attributable to the infringing activity.' Nor is
subsection (c)(1)(B) intended to cover fees based on the length of the
message (e.g., per number of bytes) or by connect time. It would
however, include any such fees where the value of the service lies in
providing access to infringing material.