Day 050 - 10 Nov 94 - Page 35

     
     1
     2   Q.   But, in terms of your opinions and your experience, you
     3        feel you have your hat on for representing advertisers,
     4        here?
     5        A.  Certainly.
     6
     7   Q.   When you represent advertisers at various places, do you
     8        particularly represent those advertisers that are
     9        affiliated to the ISBA?
    10        A.  No.  As far as possible, I try to take a view -- we, my
    11        colleagues and I try to take a view -- that is applicable
    12        to all advertisers, large or small, members or
    13        non-members.  Naturally, we only give specific advice and
    14        counsel to member companies, but we try and take a view
    15        which is representative of all companies.  It is not always
    16        easy to do that, but that is what we intend to do.
    17
    18        For example, there may be national advertisers or there may
    19        be regional and local advertisers, whose knowledge,
    20        interests and responses are different, but we try to take
         them into account as well.
    22
    23   MR. MORRIS:  I think we have no further questions.
    24
    25   MR. JUSTICE BELL:  Just sit and down and check.
    26
    27   MS. STEEL:   I wanted a bit of clarification on a legal thing.
    28        It is about the research, whether we need to ask to see it
    29        or whether we can just use the answer in summing up, or
    30        whatever you call it.
    31
    32   MR. JUSTICE BELL:  No.  You can comment in any way you want on
    33        the answer which you have, without asking what the
    34        particular research is.  But you can ask what it is, if you
    35        want, and take it from there.
    36
    37        I think the situation arose, particularly in relation to
    38        Miss Dibb, if you gave some indication that a document
    39        which was one of the documents behind her statement was to
    40        be some kind of supplementary proof.  I have probably been
         a bit slow in realising, because I have only just realised
    42        that, in fact, it has 171 references.  It is the document
    43        which I had, in fact, looked through.  I have not read all
    44        of it, by any means.  It is the first of the documents
    45        behind her statement.
    46
    47        If you either say, "We want this book or this publication
    48        to be treated as if it was supplementary proof" -- like,
    49        with a previous witness, you did -- and if that refers to a
    50        number of published papers by way of support, it really is 
    51        inviting a request: "Well, which statements in the book or 
    52        booklet are you going to rely on as, in effect, a 
    53        supplemental statement, and which of the references are you
    54        going to rely in support?"
    55
    56   MS. STEEL:  I do not think it was actually intended that the
    57        whole book was to be treated as a supplementary statement,
    58        but that is not really what I am asking now.  I am asking
    59        about -- I mean, the witness said that his perceptions of
    60        what consumers wanted, other than from an industry point of