Day 044 - 02 Nov 94 - Page 08
1 MR. JUSTICE BELL: If mine has arrived, you can have mine for
2 the time being, and I will have another when it is
3 available. Can we go on with Mr. Green?
4
5 MR. MORRIS: Yes. I probably need a couple of minutes to sort
6 my papers out.
7
8 (Short Adjournment)
9
10 MR. DAVID GREEN, Recalled.
11 Cross-examined by the Defendants.
12
13 MS. STEEL: Mr. Green, in order to increase McDonald's profits,
14 the company is trying to persuade people to eat McDonald's
15 food rather than food from any other source, are they not?
16 A. I would say that, primarily, our advertising is
17 directed towards people who already are quick service
18 restaurant-goers. That is probably the most fertile
19 ground. In fact, it is singularly the most important
20 ground, because people are already using quick service
21 restaurants. Obviously, in the United States, quick
22 service restaurants have been around for many years and
23 those who wish to go to quick service restaurants go to
24 them, and those who do not wish to do not go to them.
25
26 Q. That may be what you view as the most fertile ground, but
27 you are trying to persuade people to eat McDonald's food
28 rather than food from any other source -- not just
29 fast-food, quick service restaurants; is that right?
30 A. Certainly, our advertising reaches the entire
31 population, but it is not directed to everyone. It is
32 directed primarily to those who are already quick service
33 restaurant customers.
34
35 Q. Primarily?
36 A. Yes.
37
38 Q. But it includes others?
39 A. If others wish to come to McDonald's, they are
40 certainly welcome to come, and if the advertising gives
41 them the suggestion that they wish to try McDonald's, then,
42 absolutely, they are welcome.
43
44 Q. You are seeking to compete with other people who sell food,
45 other organisations that sell food, all other organisations
46 that sell food?
47 A. We are seeking to compete with other quick service
48 restaurants. The attributes of McDonald's are such that we
49 serve a very quick and fast meal for those that wish to
50 have it, and it is those attributes that we are trying to
51 communicate to our customers.
52
53 Q. Are you seeking to compete with all other food sellers?
54 A. I think I have tried to answer the question. Seeking
55 to compete with----
56
57 Q. "Yes" or "no"?
58 A. All customers who want to partake of McDonald's can
59 partake of McDonald's; if they wish to, that is fine. The
60 primary competition and those which the ads are targeted to
