Day 043 - 01 Nov 94 - Page 16


     
     1
     2   Q.   I see.  So one must not assume that the total for children
     3        out of national advertising was 14 per cent?
     4        A.  No.  It would be a portion:  approximately a third to a
     5        half of residuals.
     6
     7   MR. JUSTICE BELL:  But then you added a six per cent in from
     8        somewhere?
     9
    10   MR. RAMPTON:  My Lord, that was because Mr. Green said that the
    11        total for the country -- there is a split between national
    12        and local advertising.
    13
    14   MR. JUSTICE BELL:  I understand that, but where did the
    15        six per cent come from?
    16
    17   MR. RAMPTON:  I made the mistake, my Lord, of adding 11 to 3.
    18
    19   MR. JUSTICE BELL:  I followed that.
    20
    21   MR. RAMPTON:  Then I took it away from the figure of 20 which
    22        Mr. Green gave for the total, national and local added
    23        together.
    24
    25   MR. JUSTICE BELL:  But there is a local amount on adult
    26        advertising, as well.
    27
    28   THE WITNESS:  That is correct.
    29
    30   MR. JUSTICE BELL  (To the witness)  What is the six per cent?
    31        A.  Well, in general, from my recollection, about 20 per
    32        cent of all dollars that are spent are spent against the
    33        children's category.  So that would be -- you would have to
    34        add what you were spending locally.
    35
    36   Q.   So, on national advertising, we have somewhere between 11
    37        and 14?
    38        A.  That is correct.
    39
    40   Q.   On the local, you must have a much higher percentage than
    41        that spent on children if, at the end of the day, it is
    42        going to bring the children up to 20 per cent of the whole?
    43        A.  Yes.  It would be a bit higher on a local basis back in
    44        1991.
    45
    46   Q.   Yes.
    47        A.  I believe that the figures-----
    48
    49   Q.   Can I put it this way: if, overall, national and local is
    50        about 20 per cent and national is somewhere between 11 and 
    51        14 per cent, local must be comfortably above 20 per cent? 
    52        A.  I do not want to confuse you. 
    53
    54   Q.   Or it would not back the overall up, would it?
    55        A.  I am recalling these from memory.  Probably, the
    56        statement I submitted would be the best way to look at the
    57        dollars.  The 20 per cent that I am talking about is
    58        television advertising only.  The dollars which are in my
    59        statement are ones that I can rely on.
    60

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