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.
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