Day 046 - 04 Nov 94 - Page 59


     
     1
     2   MS. STEEL:  If we turn to page 20, you are moving into locations
     3        that are considered non-traditional?
     4        A.  Yes, we are moving into places where other people have
     5        been selling food.
     6
     7   Q.   "Non-traditional - shopping malls, hospital, tollways,
     8        urban areas, military bases and airports - which create new
     9        markets and increase market share and penetration".  That
    10        is the second paragraph under "Site Selection"?
    11        A.  That is correct.
    12
    13   Q.   Hospitals are not traditionally just selling food to any
    14        passing member of the public?
    15        A.  Well, in a hospital we do not sell food to any passing
    16        member of the public too, so .....
    17
    18   Q.   No.
    19        A.  People who are in the hospital.
    20
    21   MR. MORRIS:  On page 22 under Marketing, just to point out, this
    22        is marketing rather than just general competition?
    23        A.  Yes.
    24
    25   Q.   The second paragraph says, first sentence, first two
    26        sentences:  "It is our goal to communicate the McDonald's
    27        message to the broadest group of customers."  Then it
    28        says:  "That message focuses on tasty and nutritious food,
    29        friendly folks and fun.  This is a message that we
    30        articulate in a manner that is consistently aggressive and
    31        aggressively consistent".  Do you agree with that?
    32        A.  Yes, I do.
    33
    34   MS. STEEL:  There is a similar thing to the part about hospitals
    35        on page 52, just a slightly different point.  Under "Site
    36        Selection and Development":  "Most customers choose a quick
    37        service restaurant based on convenience.  Accordingly, we
    38        identify and develop sites which offer convenience to
    39        customers and long-term sales and profit potential.  We
    40        analyse traffic and walking patterns, census data, school
    41        enrolments, access and egress to assess potential".
    42         "School enrolments"?
    43        A.  Yes.
    44
    45   Q.   So, is that an indication there that you are targeting
    46        children?
    47        A.  I think that is an indication where families are, most
    48        families -----
    49
    50   MR. JUSTICE BELL:  You can tell how many children at what age 
    51        are in that particular area? 
    52        A.  That is correct.  You can get what they call census 
    53        data.  It tells you, essentially, the demographics.
    54
    55   Q.   I understand that, but you can actually get hold of figures
    56        for school enrolments in a particular area, can you?
    57        A.  I believe you can.  Again, it is not my department, but
    58        sometimes they are made available, the number of people in
    59        a particular school.
    60

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