$37B is also, IIRC, about equal to the annual income of both the recording and movie industries combined in the US...
I suppose this number has value for making a point, but in terms of practicality it is barely more meaningful than the "studies" which assume that 1 download = 1 lost, guaranteed sale. Why? Because if the legal regime were even remotely positioned to impose this sort of cost on free services, they'd fold overnight. Larry Page would be booking 100mph from his office to their nearest data center in his Tesla to personally shut down Youtube post-haste.
I get and sympathize with the propaganda value of this "study," but let's be realistic:
1. Probably only about 25% of all pirates have both the means to buy a good and would buy it if piracy weren't an option (contrary to the views of both sides).
2. In the real world, Google would either fold its operations at YouTube or would simply ratchet up the automated scanning algorithm to "guilty until proven innocent via human review."
(and 2b, Google would buy out half of Congress to make filing a false DMCA complaint be strict liability, that is absolutely no criminal intent required in order to do hard prison time for "getting it wrong.")