1. I am the Marketing Services Manager of McDonald's Restaurants Limited, which position I have held since 1991. I am 31 years of age.
2. I joined McDonald's Restaurants Limited in 1984 as a Graduate Trainee Manager. I graduated from Birmingham Polytechnic with a B.A. (Hons.) in English Language and Literature and an M.A. in Shakespeare Studies.
3. In 1986 I was promoted to the position of Store Manager and managed restaurants in Cwmbran and Weston-Super-Mare.
4. In 1988 I transferred from the Operational side of the business to the company's Marketing Department where I worked in Field Marketing in the Birmingham region for approximately 2 years. My responsibilities were for local marketing in the Birmingham region.
5. In 1989 I moved from local marketing to the Corporate Marketing Department of Head Office in East Finchley where I was responsible for Sales Promotion and Budgetary Control.
6. In 1991 a new department was created within the Marketing Services Group and I became the Marketing Services Manager with responsibilities for Research and Planning. My function was to provide interpretation and direction from internal and external management information sources for strategic planning.
7. It was in 1991 with the creation of this new Research and Planning Department that the company started to monitor continuously its customer base. Before this time ad hoc research had been conducted on a 'one off' basis but since 1991 the research has been continuously monitored augmented by ad hoc research studies on specific topics when required.
8. Like any other business, McDonald's needs to be aware of the following matters in order to operate strategically within the market place:
a. who its customers are;
b. what they think of McDonald's;
c. which other restaurants the customers are visiting.
In order to provide this information McDonald's has commissioned two companies to conduct the requisite research.
9. The first is Taylor Nelson, 'Eating Out Of Home Monitor' which is a syndicate set up by McDonald's in conjunction with other key players in the quick service/public house sectors of the eating out trade. The current format of the research conducted by Taylor Nelson was set up by my department in 1992.
10. The research is compiled by Taylor Nelson who conduct random telephone interviews to 60,000 people per year. The interviewees are asked about their eating out habits in the last week, which restaurants/pubs they visited and with whom they visited. This information is purely factual research on peoples' eating out behaviour within the last week.
11. This is the only research of its kind existing in the United Kingdom. Because (a)) other major players in the industry are part of the syndicate and (b) the sample (60,000) is very large, the credibility of this research is beyond doubt. By way of comparison Opinion Polls conducted for General Elections are frequently based on samples of 1,000.
12. In my capacity as Marketing Services Manager at McDonald's I was responsible for the setting up of the syndicate in conjunction with others within the company and I was a mayor influence on the format that it took.
13. Taylor Nelson provide the company with a quarterly presentation and report, together with hard copies of the computer tables which constitute a vast amount of documents. These are then processed by the computer from which we are able to draw tables summarising the results of the research. I attach to this statement at "AF 1" McDonald's market share tables for the three month period at May 1991, 1992, and 1993 which indicate the company's market share over time and customer profile.
14. The second way in which we monitor our customer profile is by the Fasttrack research conducted by Harris Research, a U.K. based company. This research is conducted by Harris for McDonald's in Europe; in the U.K. McDonald's buy into the pan European project. The current system or format was set up in 1992. It is a standard research project, undertaken by the vast majority of McDonald's markets.
15. Fasttrack monitors two things; (1) visitor behaviour i.e. who our customers are, with whom they visit our restaurants and the frequency of their visits; and (2) customers' opinion of McDonald's which in assessed against a set of specific attributes e.g. is it a good place for adults to eat?; is it a good place for children to eat?; party size etc.
16. This research also reveals what customers think of our competitors judged against the same attributes.
17. This research is undertaken by continuous telephone interviewing of 5,000 interviewees per annum. Harris Research report quarterly providing us with a report, a computer disk and hard copy computer table. These are then processed by the computer from which we are able to analyse the raw data and provide summaries. Attached to this statement at "AF 2" are tables for the years 1992, 1993 and 1994.
18. As well as the continuous monitoring conducted by Taylor Nelson and Harris Research, the company will also undertake "one off" projects on a specific subject. For example, in 1992 we conducted a survey on price sensitivity of the menu and the methodology used in this piece of research enabling us to establish the profile of what type of person eats the varying different types of McDonald's products. The sample was of 800 people.
19. This analysis was produced solely for the internal use of the company in the planning and positioning of brand developments. The document is an internal working document containing raw data only. Summaries have never been prepared and it is a document which is very difficult to interpret in isolation from other factors. For the purposes of this litigation I will prepare summaries but anticipate that they will not be available until the week ending 6th May 1994.
May 12, 1994|
Appeared in court|
exhibits: Not applicable/ available
transcripts of court appearances: