Day 043 - 01 Nov 94 - Page 12


     
     1        proving documents and things like that.  I mean, there have
     2        been some objections where Mr. Rampton said, I do not know,
     3        "Such and such is not proved", I do not know-----
     4
     5   MR. JUSTICE BELL:  At the end of the day, we will see what has
     6        been proved and what has not and where that takes us.
     7
     8   MS. STEEL:  Okay.
     9
    10   MR. JUSTICE BELL:  I will not rely on anything which does not
    11        have evidence to support it.
    12
    13   MR. RAMPTON:  (To the witness)  Mr. Green, if 5. 5 per cent of
    14        the US sales in 1993 was about $780 million, does that
    15        figure sound about right?
    16        A.  Yes, it does.
    17
    18   Q.   Has the proportion, round about five and a half per cent,
    19        remained the same or has it varied widely over the years?
    20        A.  It has varied in a relatively narrow range; usually
    21        between five and six per cent.
    22
    23   Q.   Has the amount that the Corporation spent -- in the USA,
    24        I am talking about -- on advertising, the amount of
    25        dollars, has that increased over the years?
    26        A.  Yes, it has.
    27
    28   Q.   If the percentage of a sales -- one can see from this table
    29        on page 135 of the pink volume III -- the sales have
    30        increased annually, except I think from -- no, they have,
    31        I think, increased annually, sometimes by more than other
    32        years.  But if the percentage is roughly constant, then the
    33        increase in the advertising spend would be roughly constant
    34        as well, would it not?
    35        A.  That is correct, yes.
    36
    37   Q.   What I want to ask you, before I move on to some detail,
    38        Mr. Green, is:  where does that $780 million come from
    39        within the organisation?
    40        A.  How are they spent or where are the sources?
    41
    42   Q.   How is it raised?
    43        A.  By contribution from the individual restaurant.
    44
    45   Q.   All over the United States?
    46        A.  That is correct.
    47
    48   Q.   Does that apply whether they are company owned or whether
    49        they are franchised, or whatever?
    50        A.  That is correct.  There is usually two ways that 
    51        dollars are raised:  one is in a local co-operative which 
    52        is in a local market area, and one is in the national 
    53        co-operative.  Those would be dollars that would be spent
    54        on a national basis.  The two combine, generate the
    55        dollars, as well as some dollars are spent at the
    56        individual restaurant in order to buy individual
    57        advertising.
    58
    59   Q.   Does the Corporation, itself, at Oak Brook near Chicago
    60        spend anything?

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