Day 013 - 19 Jul 94 - Page 23


     
     1
         Q.   But why do you see it as a war?
     2        A.  I do not know why the author of this picked that
              particular word.
     3
         MR. JUSTICE BELL:  Hold on a moment.  The first thing you
     4        should ask this witness is whether he agrees it was a
              war.  You can argue, no doubt, quite strongly that Al
     5        Smedley thought it was, but you must ask this witness.
              I have not stopped you so far.  Before you put Al
     6        Smedley's view to him, ask him if he agrees with it.  If
              he does, you can ask him why.  You seem to be assuming Mr.
     7        Horwitz is Al Smedley.  He may share his views; I do not
              know.
     8
         MS. STEEL:   One point to bring up on this.  It does say:  "We
     9        all seem to agree at the meeting the day before".
              I accept Mr. Horwitz was not there; but it is not just
    10        Mr. Smedley's view.
 
    11   MR. JUSTICE BELL:  I think it would be cautious to ask him
              before you put a view of Mr. Smedley's whether it is his
    12        view too.
 
    13   MR. MORRIS:  Do you believe you are fighting a war against your
              critics or you are being dragged into a war against your
    14        critics or you were at that time?
              A.  That would not have been my terminology had I written
    15        this memorandum.  No, is the answer to your question.
 
    16   Q.   Would you agree that one way of responding to constant
              nutrition attacks would be to sell healthy food?
    17        A.  One way, yes, that is possible, could be one way.  Do
              you mean food like meat, bread, potatoes, milk, salads?
    18
         Q.   I mean food that critics were proposing?
    19        A.  I am not sure what those foods were that you are
              talking about.
    20
         Q.   So, is it true that this was the McDonald's position, the
    21        balance position, if you like, the line?  You said you
              were developing a line.  Would you say that that was the
    22        main line: "We talk balance and moderation"?
              A.  Where are you reading now?
    23
         Q.   Say from point C:  "In balance and moderation there is a
    24        place for our food".  Would you say that is the
              fundamental line?
    25        A.  Yes, I think balance and moderation is one of the
              themes that goes through this.  Let me correct one thing 
    26        where you said before about this being McDonald's 
              position.  This is a summary opinion of one of our outside 
    27        consultants from Golin/Harris Communications, a
              communications person, to Miss Skurdy, another
    28        communications person, expressing their thoughts from a
              communications perspective.
    29
         Q.   This line of balance and moderation was the line taken up
    30        fundamentally running through the advertising campaign
              that we are about to come on to?

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