Day 046 - 04 Nov 94 - Page 05


     
     1
     2   Q.   In your opinion?
     3        A.  I think in anyone's opinion who buys advertising, it is
     4        an absolute meaningless number.
     5
     6   Q.   It is not meaningless in terms of, obviously, the quantity
     7        of ads that are put on?
     8        A.  It is meaningless not only for me, but it is
     9        meaningless for the viewer.  It is the number of people who
    10        watch an advertisement, not the number of times an
    11        advertisement is played.
    12
    13   Q.   You would never advertise on TV if you knew there were
    14        going to be no viewers, would you?  So we are not talking
    15        about a situation -- I do not know, one of the things you
    16        mentioned yesterday was that----
    17        A.  I have to just give you an example.
    18
    19   Q.   You could advertise to nobody, but there would be no point
    20        in that?
    21        A.  We advertise, for example, on a cable network -- let us
    22        say, CNN.  The rating of CNN is approximately 1/50th, maybe
    23        even less, than the rating on NBC, but we advertise there
    24        because that is the particular audience we are trying to
    25        get.  So its range is astronomical.  Some of the
    26        commercials that we buy have a 0.1 rating; other
    27        commercials have a 30 rating.  That is 300 times range.  So
    28        that is why the placement of commercials -- that is, the
    29        number of commercials that actually go on -- is a
    30        meaningless number.  You know, I am sure we can count them
    31        up, but it would be meaningless to me.
    32
    33   Q.   If someone did a survey, if they wanted to see how many
    34        times you showed your ads in a week, and they watched a
    35        channel non-stop for a week, they could discover that more
    36        of your advertisements were shown during children's time,
    37        or more advertisements were directed at children than were
    38        directed at adults?
    39        A.  I think even if you took that particular case, the
    40        substantially more occasions of commercials would go
    41        against adult.  It would be relatively in the same ratio, I
    42        would think.  It would be substantially more for adults.
    43        But I do not have that number; I have never taken that
    44        number, because it is a meaningless number.  If someone
    45        took a survey, I think they what they would want to know
    46        how many times as a customer did you see commercial, not
    47        how many times it was played.
    48
    49   Q.   You could never know how many times a customer sees a
    50        commercial unless you go out and individually ask them all? 
    51        A.  That is what the ratings services do. 
    52 
    53   MS. STEEL:   I do not think they ask everybody in the
    54        United States.  They do not ask all the children, either.
    55
    56   MR. JUSTICE BELL:  They ask, presumably, a number?
    57        A.  Yes.  In general, there is a diary that was kept.
    58
    59   Q.   Their experience tells them that is reliable enough for
    60        commercial purposes; is that right?

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