Day 045 - 03 Nov 94 - Page 42
1 A. For example, the first statement is not really true,
2 when you say "changing the way it measures success". The
3 basic tenets here of a marketing tool, a super heavy user,
4 are true and have been true for a relatively long period of
7 MR. JUSTICE BELL: Could I just give you an example? What it
8 seems to me you are putting is the proposition that
9 McDonald's is changing its focus so as to put closer focus
10 on what it calls super heavy users. Can you just take that
11 as an example of where you could ask a question?
13 MR. MORRIS: Yes.
15 MR. JUSTICE BELL: The witness could, if you chose to put the
16 document in front of him, see where it was coming from,
17 I could see where it was coming from. But you would be
18 just be asking an ordinary question as to what McDonald's
19 were or were not doing.
21 MR. MORRIS: (To the witness) For example, does McDonald's have
22 a 1995 marketing calendar -- I presume that is projected
23 intentions, for the year?
24 A. Well, it has one in progress at the moment. It has
25 been a bit delayed with me being over here, but it is in
26 progress of being put together, yes.
28 Q. It is true that it makes attempts to focus on what you
29 earlier called super heavy users?
30 A. Yes, it focuses on super heavy users.
32 Q. Or SHUs; is that correct?
33 A. That stands for "super heavy users", yes.
35 Q. Are those, typically, males, 18 to 30 years old?
36 A. It is both males and females, but I think it is mostly
37 males, or has more males than females in this category.
39 Q. I actually spoke to this journalist. She interviewed a
40 franchisee, and they said these customers eat at McDonald's
41 an average of three to five times a week and constitute an
42 overwhelming 77 per cent of sales. Is that correct?
43 A. Again, I think I mentioned before that the heavy user
44 and super heavy users, sometimes it is used
45 interchangeably, depending on what survey you are looking
46 at, but about 25 per cent of our customer base represents
47 about 75 per cent of our business. So, within that
48 context, that is close.
50 MR. MORRIS: Yes. So that last sentence, as far as you could
53 MR. JUSTICE BELL: No. I do not want to be too pedantic. Just
54 put it as a question. For instance----
56 MR. MORRIS: Would it be true-----
58 MR. JUSTICE BELL: Try not to actually quote from the article.
59 If you can extract a question, we can see what has put the
60 question into your mind. But just deliver the question.