Day 258 - 07 Jun 96 - Page 27


     
     1
     2   MS. STEEL:   Are we on the first page?
     3
     4   MR. RAMPTON:  Second page.  --  is basically the number of
     5        people that use McDonald's one or more times in a year?
     6        A.  That is correct, yes.
     7
     8   Q.   Can you turn back then, please, to AF1, at page 5 of AF1,
     9        where we are being shown what percentage share of the
    10        eating out market is constituted by different kinds of
    11        establishments?
    12        A.  Yes.
    13
    14   Q.   If you look at page 7 for three comparable periods at three
    15        different years, roughly speaking, McDonald's has, or had,
    16        70 per cent of the burger market?
    17        A.  That is correct, yes.
    18
    19   Q.   If you go back then to page 5 of AF1, I can tell you -- you
    20        probably can work it out in your own mind -- 70 per cent of
    21        8 per cent is 5.6 per cent?
    22        A.  Yes.
    23
    24   Q.   So McDonald's has 5.6 per cent, or did at this date, of the
    25        total eating out market?
    26        A.  That is correct, yes.
    27
    28   Q.   This question may be important, and perhaps blindingly
    29        obvious, do these AF1 documents measure feet through the
    30        door of volume of sales?
    31        A.  AF1 measures feet through the door, that is correct;
    32        measures feet through the door, yes.
    33
    34   MR. JUSTICE BELL:  Keep your voice up.  Measures feet through
    35        the door?
    36        A.  Yes.
    37
    38   MR. RAMPTON:  In what sense?
    39        A.  It measures claimed visits to eating out establishments
    40        by members of the public who eat out.
    41
    42   Q.   So, can you explain how it is, unless there is something I
    43        have missed, this gives McDonald's 5.7 per cent of the
    44        eating out market whereas AF3, second sheet, gives
    45        McDonald's something like 50 per cent, just under 50 per
    46        cent?
    47        A.  I can explain no direct link between them because there
    48        is no direct link.  AF1 is produced in a format of data
    49        that is designed to give us our share of the market place,
    50        AF3 was produced in response to a specific question which 
    51        was, could we work out how many individuals were 
    52        represented by frequency groups within our own user base. 
    53        The calculations on AF3 was our response to that.
    54
    55   Q.   I understand that.  But what I am wondering is, it is quite
    56        obvious, perhaps, to everybody that we are comparing apples
    57        and oranges, but I am wondering if you can explain the
    58        difference.  What are the apples?  If the apples are AF3,
    59        I understand what they are, which gives McDonald's, on that
    60        view, frequency of visits in the course of a year something

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