Day 054 - 24 Nov 94 - Page 27
1
2 Q. It is not specifically about their advertising, but how
3 does that relate to their advertising, in your opinion?
4 A. This is part of their promotional strategy. Their
5 adverts are part of their promotional strategy as well.
6 The link between the use of ronald mcdonald in commercials
7 and his use in live personal appearances is obviously going
8 to be very close.
9
10 Q. They work together, do they?
11 A. Certainly, any marketing strategy (and McDonald's, I am
12 sure, is no exception) ensures that all the elements of it
13 build on each other and complement each other.
14
15 Q. Mr. Ken Miles, do you know Ken Miles?
16 A. I know of him, yes.
17
18 Q. He says in his -----
19
20 MR. JUSTICE BELL: I take it to mean you know who he is but you
21 have not had any personal or professional dealings with
22 him?
23 A. I have met him on occasions at conferences. I do not
24 know him personally but I have met him.
25
26 MR. MORRIS: When I put this to Mr. Miles, he said, to summarise
27 -- I am sure if I get it wrong the Plaintiffs will correct
28 me -- "If an attempt was made in an advertisement to create
29 love by a child, it would be something that the ITC would
30 want to look at very carefully, be taken seriously". When
31 I put that point to him there, he said: "I think they are
32 saying something like that, but what they do in internal
33 company documents is a different matter from what they do
34 specifically in ads". Do you think the ITC in their
35 current guidelines should be concerned about this kind of
36 promotional approach?
37 A. Are you asking me whether there should be guidelines or
38 -- sorry, I do not understand the question.
39
40 Q. I think it relates to the guidelines in general -- we will
41 come to that later on -- but they had guidelines which are
42 concerned about, for example, exploiting children's loyalty
43 or strong emotions. Does it make a difference to you, does
44 it mean that it is not important if they maybe doing that
45 but if they are not actually specifying in the ads: "You
46 should love ronald mcdonald" or -- do you see what I am
47 saying? My question is very poor but, I mean, make some
48 comment on that.
49
50 MR. JUSTICE BELL: I think what is being put to you, it has been
51 suggested that you might give an answer to the effect that
52 if, albeit that is in an internal document, it might be
53 indicative of what they are really trying to do and,
54 although it is related to in-store activities there, it may
55 be indicative of what they are trying to do in the
56 television ads?
57 A. Yes, I would agree that this is indicative of what they
58 are trying to do in their promotions which would include
59 their advertisements. I think this would not be permitted
60 if it were in an advertisement. Therefore, I think it does
