Day 048 - 08 Nov 94 - Page 56


     
     1   Q.   When you were answering questions from the defendants not
     2        long ago, you said you can not just look at the number of
     3        weeks to decide what the true effect or value of the
     4        advertising is to you and you were not permitted to give an
     5        explanation why that is so. Would you tell us now why weeks
     6        is not the best measure of value so far as you are
     7        concerned?
     8        A.  Because what one is buying is an audience.  You are
     9        buying people and therefore, you have to look at the
    10        different ratings and weights of advertising that is taking
    11        place.  Not just how many spots happen to be going out
    12        during how many weeks.
    13
    14   Q.   You mentioned at one stage in your cross examination the
    15        word 'exposure,' what is meant by that?
    16        A.  Simplistically, it is the number of times one could be
    17        exposed to a particular commercial.
    18
    19   Q.   Is there perceived to be a difference at different times of
    20        the day or to different audiences of the frequency of
    21        exposure?
    22        A.  Yes.  That would vary by day.  It would also vary by
    23        campaign.
    24
    25   Q.   Does it vary as between children and adults?
    26        A.  In terms of frequency?
    27
    28   Q.   Frequency?
    29        A.  Yes, we would buy them differently.
    30
    31   Q.   What would the difference be? Which is the greater,
    32        children or adults?
    33        A.  In terms of our frequency of advertising, across the
    34        years it would be more to do with adults than to do with
    35        children.
    36
    37   Q.   One notices at the bottom of this chart that what I think
    38        you call the universe for children in London, putting TV AM
    39        and ITV and Channel 4 together, is £862,000?
    40        A.  Yes, according to these figures.
    41
    42   Q.   And that for adults it is 5,350,853 people; is that right.
    43        A.  Yes.
    44
    45   MS. STEEL: I think that is the prices isn't it
    46
    47   MR. RAMPTON: Is that the expenditure, perhaps. I don't know.  I
    48        haven't added them up.
    49
    50   MS. STEEL: It is the prices. 
    51 
    52   MR. RAMPTON: Let's turn back to another year where we can find 
    53        what we----
    54
    55   MR. JUSTICE BELL: While you are just looking for that, may I ask
    56        a question about your answer or part of your answer to the
    57        great cost of adult advertising - because it is a more
    58        lucrative market for the majority of advertisers to reach
    59        adults.
    60        Now, one might treat that answer in this context.  You want

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