Day 046 - 04 Nov 94 - Page 29


     
     1        have a quick look through these documents, to remind
     2        yourself.
     3        A.  Again, it is difficult to remember every single
     4        meeting, but the ads may have been discussed, which ads
     5        were approved, and then if there was any revisions or
     6        discussions as to the insertion schedule.
     7
     8   Q.   What would have been discussed about each ad, apart from
     9        just when it was going to be shown-----
    10        A.  We would------
    11
    12   Q.   ----at that kind of meeting?
    13        A.  We would have looked at each ad, made sure that the ad
    14        was correct, that our experts had looked at the ad, that
    15        they had given us their feeling that the ad was correctly
    16        stated.  If there were any controversies about any
    17        statement in the ad, they would be discussed; and, in
    18        general, whether we liked the ad.
    19
    20   Q.   Right.
    21        A.  Then we would also discuss how the ads were to be run.
    22
    23   Q.   I believe you said that the ads continued -- "We are going
    24        to follow that up with the ads series" -- and that
    25        continued for a year, or-----
    26        A.  I believe these ads continued for about a year, and
    27        then there was another set of ads that continued the next
    28        year.
    29
    30   Q.   So that might have been something that would have been
    31        discussed, the schedule of the ads?
    32        A.  Yes.
    33
    34   Q.   The long term schedule, not just the immediate schedule?
    35        A.  Yes.  As we got closer to when the actual time would be
    36        that we insert the ads, then the media plan would have been
    37        drawn up, and we would have discussed what magazines would
    38        they go in and, you know, how many times they may run in
    39        that particular magazine, and the strategy of, you know,
    40        the single page versus the double page.
    41
    42   Q.   When you said you would discuss the content of the ads,
    43        whether you agreed with them, legal considerations, and
    44        that kind of thing?
    45        A.  Yes.  It was more than just-----
    46
    47   Q.   Was there a concern that, because you had criticisms, that
    48        you wanted them not to be deceptive, or whatever?
    49        A.  Yes.  We wanted the ads to represent the consensus of
    50        opinion of experts that we had to talk with about the ads. 
    51 
    52   MR. MORRIS:   So had you taken advice before this?  I think we 
    53        have documents on that, anyway.
    54
    55   MR. JUSTICE BELL:  Can you remind me -- you do not have to look
    56        it up now -- when the eminent-----
    57
    58   MR. MORRIS:  Harvey Anderson.
    59
    60   MR. JUSTICE BELL:  Yes, that is right.

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