Day 043 - 01 Nov 94 - Page 11

     
     1        at the bottom of the page -- have you got a table headed
     2        "11 Year Summary"?
     3        A.  Yes, I do.
     4
     5   Q.   At the top of the page, the first column -- this is the
     6        annual report for 1993 -- gives US sales, the second item,
     7        as virtually $14.2 billion, does it not?
     8        A.  That is correct.
     9
    10   Q.   How is it that in the document we have just looked there is
    11        such a gross underestimate?
    12        A.  It is my belief that they did not pick up the full
    13        United States sales.  They picked up the revenue to the
    14        Corporation.
    15
    16   Q.   If we are making a comparison or trying to work out what
    17        percentage of sales is spent by the Corporation or by the
    18        organisation on advertising, which figure should we take as
    19        being the reliable figure for sales?
    20        A.  It would be the annual report; it would be the total
         sales.
    22
    23   Q.   You told us that a rough figure for expenditure on
    24        advertising and promotion annually would be about five and
    25        a half per cent?
    26        A.  That is correct.
    27
    28   Q.   I save you the trouble, I hope, that five and half per cent
    29        of about 14.2 billion is about $780 million.  Does that
    30        sound about right?
    31        A.  That is correct.
    32
    33   MS. STEEL: Can I just clarify something?  I am bit uneasy about
    34        what is going on, that this chart was called to prove
    35        something and now it is being said that the figures are
    36        inaccurate.  I mean, what is the point in the chart?
    37
    38   MR. RAMPTON:  The point of the chart was supposed to be to
    39        provide a comparison -- in fact, it may still do so -- but
    40        the fact is that the figure given for the amount of US
         sales in the chart is wrong by a factor of about 75 per
    42        cent or something.
    43
    44   MS. STEEL:  It means the chart is useless.
    45
    46   MR. JUSTICE BELL:  That may entitle you in due course to argue
    47        that the whole chart is completely useless.
    48
    49   MR. MORRIS:  We do not know the Wendy calculation, either.
    50 
    51   MR. JUSTICE BELL:  I know.  This is, I am afraid, for comment in 
    52        due course.  I know it is irritating to be told that you 
    53        can make the point at the end of the day, but we are
    54        hearing the evidence now and, in due course, you will be
    55        entitled to argue, if you wish, that I should pay no
    56        attention whatsoever to the chart.  Mr. Rampton will have
    57        his argument in relation to it.  I cannot sort it out now,
    58        because I have not heard all the evidence.
    59
    60   MS. STEEL:  I just sort of wondered about the thing about