Day 043 - 01 Nov 94 - Page 22

     
     1        A.  They would be fourth or fifth.
     2
     3   Q.   Hardee's?
     4        A.  Right after Wendy's.
     5
     6   Q.   So of the top six, four are burger houses, roughly
     7        speaking?
     8        A.  That is correct.
     9
    10   Q.   This may seem a surreal question, Mr. Green, but it may
    11        have some significance after all.  What do you think would
    12        happen to McDonald's share of the market, whether it be the
    13        quick service market or the smaller burger market, if
    14        McDonald's stopped advertising?
    15        A.  I think it would drop.  Obviously, advertising is
    16        important to keep your message in front of the consumer and
    17        to ensure that you get patronage from people who are part
    18        of the quick service restaurant market.
    19
    20   Q.   Is the QSR sector a competitive one in America?
         A.  Fiercely competitive.
    22
    23   Q.   I suppose this follows from the fact that three of your
    24        main rivals are burger houses, but the burger sector is
    25        also competitive?
    26        A.  Very competitive.
    27
    28   Q.   Do Burger King, for example, advertise a lot in the
    29        United States?
    30        A.  Yes, they do.
    31
    32   Q.   On television?
    33        A.  Yes.
    34
    35   Q.   To children?
    36        A.  Yes.
    37
    38   Q.   Do you -- you may hope that you do -- have any evidence
    39        that your advertising pulls in customers from a
    40        significantly wider section of the population than those
         who eat in the quick service restaurants sector?
    42        A.  Mostly, information that I have is that most of the
    43        heaviest users of McDonald's are in the quick service
    44        restaurant category already, and those are the people that
    45        are most influenced and that we target our advertising to.
    46
    47   Q.   I want to ask you, if I may, about children's advertising.
    48        What, to your mind, is meant by children's advertising?
    49        A.  Well, in its simplest form, it is advertising that is
    50        placed in the media and directed to children. 
    51 
    52   Q.   What do you mean by "children"? 
    53        A.  "Children", it is sort of a broad category of age
    54        groups.  We sort of divide it up into two categories.  One
    55        would be what we call Ronald-aged children, or children
    56        that enjoy Ronald commercials, and that would go to
    57        somewhere around eight or nine, maybe 10 years at the most;
    58        then we have what we call "tween advertising", a sort of a
    59        word to denote that they are in between: they are too old
    60        for Ronald and too young for the car keys, is sort of how