Day 037 - 14 Oct 94 - Page 12


     
     1        direct marketing, direct mail, where there the advertising
     2        costs are indeed very high because they, essentially, are
     3        the same as another industry's retail costs, for example.
     4        A direct mail company does not have high street shops;
     5        therefore, it can afford to spend more money promoting
     6        itself.  But five per cent I would consider to be very
     7        high for this type of industry.
     8
     9   Q.   Much of this advertising obviously is not in this country,
    10        that budget.
    11
    12   MR. JUSTICE BELL:  I do not want to take you off your line, but
    13        I really am most interested in the specifics.  In fact,
    14        your own witness has tried to steer it in that direction a
    15        few minutes ago.  Do take any general point.
    16
    17   MR. MORRIS:  Just the last general point:  Is there an effect
    18        on the culture of a country, its volume?
    19        A.  Yes.
    20
    21   Q.   Or can there said to be?
    22        A.  I would put it more strongly than that.  I would say
    23        it is an essential part of McDonald's marketing platform
    24        to alter the culture of entire nations, and I think there
    25        is no disputing that that is one of their objectives.
    26        I would like to introduce at this point my reason for
    27        saying that, which is a book that I read a number of years
    28        ago, certainly before this whole action started, which I
    29        understand has been entered into the court called
    30        "McDonald's:  Behind the Arches".  There are a number of
    31        quotations from that I would like to briefly discuss, if
    32        I may?
    33
    34   Q.   I do not know whereabouts in the court files it is.  It
    35        might be useful -- it is in the Defendants' documents
    36        somewhere.  I do not know if the index covers our
    37        document.
    38
    39   MR. JUSTICE BELL:  Shall I take that on the same basis that
    40        I took ------
    41
    42   MR. RAMPTON:  My Lord, these are probably what the witness is
    43        referring to, I do not know.
    44
    45   MS. STEEL:  They look like it.
    46
    47   MR. JUSTICE BELL:  On the same basis that I have got
    48        Dr. Barnard's book; if I mark it I will mark it in pencil.
    49
    50   MR. RAMPTON:  It may be, my Lord, without being suspected of 
    51        trying to bribe the judiciary, we can give you one. 
    52 
    53   MR. JUSTICE BELL:  I am only going to read those bits I am
    54        specifically referred to by Mr. Morris, Ms. Steel or
    55        yourself, Mr. Rampton.
    56
    57   MR. RAMPTON:  Your Lordship can make whatever marks or comments
    58        on it you think fit.  Can I pass one up for the witness?
    59
    60   MR. MORRIS:  He has got our copy.  We do not want to spend too

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