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
     5        time.
     6
     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?
    12
    13   MR. MORRIS:  Yes.
    14
    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.
    20
    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.
    27
    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.
    31
    32   Q.   Or SHUs; is that correct?
    33        A.  That stands for "super heavy users", yes.
    34
    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.
    38
    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.
    49
    50   MR. MORRIS:   Yes.  So that last sentence, as far as you could 
    51        see----- 
    52 
    53   MR. JUSTICE BELL:  No.  I do not want to be too pedantic.  Just
    54        put it as a question.  For instance----
    55
    56   MR. MORRIS:  Would it be true-----
    57
    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.

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