What's also evident is that some films lend themselves to day and date more than others. Laub points to two recent Oscilloscope releases to prove this point. They decided not to do a day and date release for "Mother of George," because "it's not an automatic draw," said Laub. "We loved the movie when we saw it and the reviews exceeded our expectations, but it needs to be nurtured."
A film like "28 Hotel Rooms" was a natural for day and date release, said Laub, pointing out that its title was a big plus (films that start with numbers or letters early in the alphabet tend to do well on VOD).
"About Cherry," starring James Franco, Heather Graham and Dev Patel, opened in only three theaters last year, but scored on VOD, where it made over $500,000 in the first week across all VOD platforms, according to the film's distributor IFC Films.
But a successful VOD run and a successful theatrical run don't have to be mutually exclusive; one benefit of a day-and date release is the publicity surrounding the theatrical release also benefits VOD platforms.
"You can still be successful in both realms if you have the right marketing campaign, the right film and the right release strategy. They can feed each other," said Laub.
"Margin Call," the 2011 film directed by J.C. Chandor and starring Kevin Spacey, Stanley Tucci, Paul Bettany and Jeremy Irons, was a high-profile example of a film that had success in both theaters and on VOD. But even with that film, there's a question of whether it would have done better in the theater had it not been available on VOD.
Unlike theatrical releases where box office receipts are publicly reported, in general, VOD numbers are not released, which makes it tricky to gauge success -- except when companies choose to trumpet their successes.
That may change; John Sloss led the charge by releasing VOD figures for "Escape from Tomorrow" and urging other distributors to do the same. Radius-TWC followed suit by releasing the VOD figures for "Man of Tai Chi," which went the ultra-VOD route.
Gallagher points to "The Perfect Family," starring Kathleen Turner, Emily Deschanel and Jason Ritter, which was released on VOD and in theaters in May 2012, as a day and date success story, saying it did "over six figures in the theater and very, very well on VOD."
Releasing a film theatrically is expensive; historically, if the theatrical release wasn't a success, distributors would have to wait three months or longer to release the film on DVD or elsewhere. But now, distributors can coordinate all of the publicity efforts for the theatrical release to include the on-demand release.
"Most independent films aren't sitting on large marketing budgets, so to be able to market both a theatrical and VOD release at the same time is very efficient," said Gallagher.
Built-in name recognition or name stars also help VOD titles (as opposed to something like "Mother of George," where the title doesn't indicate exactly what it's about and there are no stars in the cast).
Berry Meyerowitz, president and CEO at Phase 4, points to the "ultra" release of films like "Only God Forgives" as leading the charge.
"When you have big stars like Ryan Gosling in movies going on demand, people are starting to get it," he said. "Movies that have done well on VOD have titles where you know exactly what it's about, like 'Assault on Wall Street.' "The more descriptive we can be, the better."
In the past, filmmakers might be reluctant to have a day and date release and some do still prefer theatrical windowing. But, as Laub points out, "A lot of filmmakers are increasingly open to these new models.
Terence Malick's last movie ("To The Wonder") was released day and date in April. There are legitimate success stories with films like 'Margin Call,' which went day and date. I've seen more openness to it over time."
In the case of "Good Ol' Freda," director Ryan White had no problem with the film being released day and date, especially since music documentaries tend to do well in VOD.
"Our niche audience is Beatles fans who are throughout the country. It's a film for the fans. I didn't just want it to be available to people in the big cities. We wanted it to be democratic, with people being able to see it right away," White told Indiewire.
"More and more filmmakers understand," said Meyerowitz. "Exhibitors are starting to understand as well. If it's going to work, we need more exhibitors to buy into the notion that a bigger pie is better for everyone. Some movies will find an audience on demand and some movies will find an audience in theaters."
Of course, the less of a stigma there is surrounding a VOD or day-and-date release, the more VOD releases we'll see -- especially as fewer small films have a shot at theatrical distribution -- which means there's already a glut of VOD releases vying for attention.
So is VOD the future for indies? Only time will tell.