Day 046 - 04 Nov 94 - Page 05
1
2 Q. In your opinion?
3 A. I think in anyone's opinion who buys advertising, it is
4 an absolute meaningless number.
5
6 Q. It is not meaningless in terms of, obviously, the quantity
7 of ads that are put on?
8 A. It is meaningless not only for me, but it is
9 meaningless for the viewer. It is the number of people who
10 watch an advertisement, not the number of times an
11 advertisement is played.
12
13 Q. You would never advertise on TV if you knew there were
14 going to be no viewers, would you? So we are not talking
15 about a situation -- I do not know, one of the things you
16 mentioned yesterday was that----
17 A. I have to just give you an example.
18
19 Q. You could advertise to nobody, but there would be no point
20 in that?
21 A. We advertise, for example, on a cable network -- let us
22 say, CNN. The rating of CNN is approximately 1/50th, maybe
23 even less, than the rating on NBC, but we advertise there
24 because that is the particular audience we are trying to
25 get. So its range is astronomical. Some of the
26 commercials that we buy have a 0.1 rating; other
27 commercials have a 30 rating. That is 300 times range. So
28 that is why the placement of commercials -- that is, the
29 number of commercials that actually go on -- is a
30 meaningless number. You know, I am sure we can count them
31 up, but it would be meaningless to me.
32
33 Q. If someone did a survey, if they wanted to see how many
34 times you showed your ads in a week, and they watched a
35 channel non-stop for a week, they could discover that more
36 of your advertisements were shown during children's time,
37 or more advertisements were directed at children than were
38 directed at adults?
39 A. I think even if you took that particular case, the
40 substantially more occasions of commercials would go
41 against adult. It would be relatively in the same ratio, I
42 would think. It would be substantially more for adults.
43 But I do not have that number; I have never taken that
44 number, because it is a meaningless number. If someone
45 took a survey, I think they what they would want to know
46 how many times as a customer did you see commercial, not
47 how many times it was played.
48
49 Q. You could never know how many times a customer sees a
50 commercial unless you go out and individually ask them all?
51 A. That is what the ratings services do.
52
53 MS. STEEL: I do not think they ask everybody in the
54 United States. They do not ask all the children, either.
55
56 MR. JUSTICE BELL: They ask, presumably, a number?
57 A. Yes. In general, there is a diary that was kept.
58
59 Q. Their experience tells them that is reliable enough for
60 commercial purposes; is that right?