Day 044 - 02 Nov 94 - Page 43

     
     1        restaurant and want to come back.
     2
     3   Q.   We are talking here, are we not, about very young children;
     4        ronald mcdonald is geared to two to eight year olds, you
     5        said yesterday; is that correct?
     6        A.  I am not sure I said that, but I agree that is the
     7        general age group.
     8
     9   Q.   So, in other words, you are focusing, with this part of
    10        your promotional activities, on the most vulnerable section
    11        of our society; is that correct?
    12        A.  I am not sure what you mean by "most vulnerable".
    13
    14   Q.   Would you say that children between the age of two and
    15        eight are the most vulnerable section of our society?
    16        A.  I am not sure what you mean by "vulnerable".
    17
    18   Q.   Would you say that they are a very vulnerable section of
    19        our society?
    20        A.  Again, I do not know how you are using the term
         "vulnerable".
    22
    23   Q.   Would you say they are very impressionable?
    24        A.  Certainly, they are impressionable, yes.
    25
    26   MR. JUSTICE BELL:  What, I think, is being put to you is that
    27        children are particularly easy to impress via advertising
    28        or in any other way.  Do you agree with that?
    29        A.  I think that children are relatively easier to impress
    30        than maybe someone who is older, but I do believe -- at
    31        least, from my point of view and my experience -- that
    32        children are fairly sophisticated about what they like or
    33        what they do not like.  The most impressionable, which
    34        would be the very young children, really, I believe, look
    35        at McDonald's and McDonald's advertising as entertainment,
    36        and not much more than that.
    37
    38        If you see our advertising, I think you would agree that we
    39        take great care that, when we advertise to children, we do
    40        it in a very pro-social way and in a way that would be in
         keeping with the values that their parents would have.
    42
    43   MR. MORRIS:  This is the sales and marketing section of the
    44        McDonald's Corporation Operations Manual for all store
    45        owners and managers?
    46        A.  That is correct.
    47
    48   Q.   So your department has to reflect this, does it not?
    49        A.  It is certainly part of it.  Our department did not
    50        write it, but I think it reflects what our department does, 
    51        yes. 
    52 
    53   Q.   Do you know who wrote it?
    54        A.  The Operations department.
    55
    56   Q.   So ronald mcdonald -- in fact, when you say you are
    57        advertising for children about entertainment, I think
    58        yesterday you said something different; you said it was
    59        about information.  But on this page, page 154, it says
    60        that ronald mcdonald is a strong marketing tool.  Is that