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Hi Erica Ferguson,
The simplest way to do this is to use a score field. You increment it by 1 each time the person attends, and when you threshold is reached, you filter the leads (from invitations and/or registration).
You can even decrease the score if the person remains inactive for a while.
Are you using GoToWebinar? If so, then you can change your settings from automatic approval to manual approval and refuse to approve people who are not truly interested in your product. This is not ideal with very large registrations (such as webinars that routinely pull 3K+ registrations), but if the audience is smaller it might be feasible to do this.
I can't think of a filter that would grab this with a smart list unless it's somehow reflected in your scoring model and you can use that as a filter (but that might block good leads that are new to your org with lower scores and just starting to view webinars).
You might try creating a custom field and use that as a filter. Something like "Lead Status" or "Contact Status" = "dead" or "bad fit" that indicates that they will never buy from you, so they aren't in need of more nurturing, they simply are not a good lead to pursure and you don't want to waste time and resources on them. That way your sales team can help tag these as time goes on.