Day 045 - 03 Nov 94 - Page 36

     
     1   Q.   Issuing press releases, and things of that kind.
     2        A.  Yes, on local co-op basis, the five to six per cent
     3        would pay for the fee, to have both the advertising agency
     4        and the public relations agency.  Have I answered that?
     5
     6   Q.   Does your Communications department issue press releases?
     7        I do not know whether you call them press releases in the
     8        States?
     9        A.  Yes.  The Communications department does, and the
    10        actual cost of the Marketing department and the
    11        Communications department -- we call it G and A, that is in
    12        the United States -- is not included in the 5.5 per cent on
    13        a national basis, but it is included in the 5.5. per cent
    14        on a local basis.  I think we pointed that out yesterday in
    15        the report, that my department has a separate budget than
    16        the national co-op, but that is not true on a local co-op
    17        basis.
    18
    19   Q.   So if we take the five to six per cent, that covers local
    20        public relations?
         A.  That is correct.
    22
    23   Q.   Any local press releases?
    24        A.  That is correct.
    25
    26   Q.   Any national ones come out of that $80 to 90 million?
    27        A.  That is correct.
    28
    29   Q.   I forget if I have figure right or not -- which is in
    30        addition to the five to six per cent?
    31        A.  Yes, it is.
    32
    33   MR. MORRIS:  It says 80 to 90 million.  It was 18 to 19, was it
    34        not?
    35        A.  No.  I do not remember from memory.  It was, I think,
    36        somewhere between $60 and 70 million, back in the 1991
    37        OPNAD annual report.
    38
    39   MR. JUSTICE BELL:  You said 80 to 90 in paragraph 6 of your
    40        statement.
    41
    42   MR. MORRIS:  So your department is the Marketing department?
    43        A.  Yes, that is correct.
    44
    45   Q.   So when the company says it spends -- I cannot remember
    46        what the figure was -- something like $700 million on
    47        advertising, whatever it was, $786 million dollars,
    48        whatever, in the States----
    49        A.  Yes.
    50 
    51   Q.   ----the general marketing costs, such as that 
    52        $80 to 90 million, are not included in that? 
    53        A.  That is correct.  That is in addition to that number.
    54
    55   Q.   That 80 to 90 million is the national marketing cost?
    56        A.  Yes.  That pays for the people in my department; it
    57        pays partially for some of the fees for the advertising
    58        agency.  But the greater predominance -- in fact, the vast
    59        majority -- is to pay for the creative materials.
    60