Day 046 - 04 Nov 94 - Page 68
1 this, that may be so -----
2
3 MS. STEEL: Can he not ask what his response is rather than ask
4 him a leading question?
5
6 MR. RAMPTON: No. If I have summarised incorrectly, I am trying
7 to save time -- I think your response (and you will correct
8 me if I am wrong) is: "That would be nice if it were so,
9 but so far as I, the advertising department at McDonald's
10 Corporation is concerned, we do not target the whole world,
11 we target particular sections; is that right?
12 A. Yes, I think that is accurate.
13
14 Q. In particular, we target the quick service restaurant
15 sector?
16 A. I have said that several times.
17
18 MR. MORRIS: There was an objection to leading questions when
19 I did re-examination to save time.
20
21 MR. JUSTICE BELL: The reason I have not interrupted is that I
22 have a very clear picture of what the witness has said in
23 the event, so I do not think it is going to do any harm in
24 the end. You are quite right, it is a leading question.
25
26 MR. MORRIS: I do remember when I was trying to save time
27 specifically, I did say that I would like to ask a few
28 leading questions. I do not mind as long as it applies to
29 both parties.
30
31 MR. RAMPTON: I hope your Lordship will intervene if ever I ask
32 a leading question when I should not do. Your Lordship
33 will notice that my question is not a leading question.
34 (To the witness): Mr. Green, if it were your function as
35 the advertising department of McDonald's Corporation to
36 target the whole eating out market in America, would that
37 involve any differences in the way in which you advertised
38 your products?
39 A. Yes, it would.
40
41 Q. With specific reference to television advertising first, in
42 general, both adults and children, what sort of differences
43 would you expect to have to introduce?
44 A. Well, very specifically we would try to compare very
45 specifically eating out at a white table cloth restaurant
46 versus eating at McDonald's, or we would compare other
47 things that would not be specifically against the quick
48 service restaurant business or the attributes that we have.
49
50 Q. Do you think (and I know this is a speculation, but you
51 have some experience in the field) that there would be any
52 marked or significant differences in the way in which you
53 advertise your products to children?
54 A. We certainly -- you know, if we were trying to make a
55 difference or a comparison with products or a family eating
56 at home, we might show them eating at home and saying:
57 "No, I would rather go to McDonald's" but we do not do
58 that.
59
60 Q. That is the first thing. The second thing is this, arising
