Day 046 - 04 Nov 94 - Page 72


     
     1        second column -- take, for example, the 0 to 7s, do you
     2        see?
     3        A.  Yes.
     4
     5   Q.   In the bottom table, "1991 Summary of visitation by age"?
     6        A.  That is that is correct.
     7
     8   Q.   We see that the number of annual visits for that age
     9        category, 0 to 7, was 420.9 (sic) million, was it not?
    10        A.  Yes.  420.9, excuse me?
    11
    12   Q.   Sorry.  520.9.
    13        A.  520.9.
    14
    15   Q.   Then we jump a column, and we see that the US population
    16        for that age group, in other words, number of 0 to 7s in
    17        the population at large is 29.6 million?
    18        A.  Yes.
    19
    20   Q.   If you divide 29.6 million into 520.9 million, you in
    21        fact -- and I can tell you, because I have done the thing
    22        on a calculator -- you get a figure of 17.6?
    23        A.  That is correct.  I believe that was my definition.
    24
    25   Q.   I think they have used the same method.
    26        A.  Yes.
    27
    28   Q.   What we find here is, is it -- and this is what I am
    29        asking -- the column "per capita visits" represents an
    30        estimate of the number of visits made by every child in the
    31        population in that age group per year to McDonald's?
    32        A.  An average.
    33
    34   Q.   An average?
    35        A.  That is correct.
    36
    37   Q.   That is an average?
    38        A.  Yes.
    39
    40   Q.   Of course.  So that there would be some who go not at all,
    41        or very seldom, and some who go much more often?
    42        A.  That is correct.
    43
    44   Q.   We can see, if we do what you call the math, that for the
    45        age group 0 to 13, the average number of visits annually
    46        per child in that age group is 16.7?
    47        A.  Yes.  You would add up the population, which would be
    48        the 29.6 or 21.4, and you would add up the visits, and you
    49        would do division; and if you did the division, I rest on
    50        your feeling or your judgment. 
    51 
    52   Q.   If you do the calculation for the age group 0 to 17, again 
    53        adding up the visits and then dividing them by the total
    54        amount of population in those age groups, you get a figure
    55        of 18.2, average number of visits per year per child?
    56        A.  This would be the most accurate way to do that.
    57
    58   Q.   Is that what you were thinking of when you gave the figure
    59        of roughly 20?
    60        A.  Yes; roughly 20 was what I was thinking of, and these

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