Day 048 - 08 Nov 94 - Page 19
1 taking the witness through the documents, in a way which
2 Ms. Steel can quite easily can do with your Lordship, if
3 the witness is to make a useful contribution to the
4 proceedings, which is why he is here, he should be asked a
5 question, not just, "It says so and so many weeks, does it
6 not", and the witness says, "Yes, it says so and so many
7 weeks." The question is as to what that means.
8
9 MS. STEEL: (To the witness) It means that there are more weeks
10 in which advertising is directed at children than there are
11 adults, does it not -- at young children?
12 A. Well, the young children, I do not know, because I do
13 not know what the buying strategy was at this time. There
14 are more weeks aimed at children here in this line than
15 there are adults, yes; it is self-evident.
16
17 MR. MORRIS: Could I just say something? In your figures which
18 you use to justify the point at issue in the case, you
19 relied solely on expenditure, did you not?
20 A. Yes.
21
22 MR. RAMPTON: Again, my Lord, that is not fair. Mr. Hawkes has
23 written in his statement that he adopts, save in so far as
24 there are differences to which he has pointed, what
25 Mr. Hayden has said. In Mr. Hayden's statement----
26
27 MR. JUSTICE BELL: I think the witness should answer,
28 Mr. Rampton, rather than you.
29
30 MR. RAMPTON: It just is not fair.
31
32 MR. JUSTICE BELL: (To the witness) What do you say about that?
33 It was put as a statement, but it was meant to be a
34 question. Is it right that in the figures which you use,
35 that is to get a proportion of advertising directed at
36 children and adults, you are relying solely on expenditure?
37 A. That was -- yes, that was the statement that I took
38 over, and that is what I agreed with, yes.
39
40 MR. MORRIS: Right. It is not the only way of looking at it, is
41 that correct; it is not the only way of looking at it, is
42 it?
43 A. Of course not. There is a myriad of ways----
44
45 Q. In fact, it may not even be the most useful way of looking
46 at it. In fact, it might be a completely misleading way of
47 looking at it?
48 A. No. I do not think it is misleading. It is a
49 statement of fact.
50
51 Q. We are not concentrating on expenditure now, are we; we are
52 concentrating on exposure, are we not?
53 A. Weeks, I think, yes.
54
55 Q. Weeks is one measure of exposure. Another measure of
56 exposure is rating points. You said something like 4,000
57 to 8,000; is that correct? That is now, you would say, a
58 more effective measure than just money spent?
59 A. Communications, yes, the numbers of ratings that you
60 get to a particular target audience.
