Day 045 - 03 Nov 94 - Page 25
1 Q. So would it be fair to say that although virtually every
2 child may have been to McDonald's at one time, a child that
3 would be visiting fairly regularly would actually be a very
4 small percentage of children?
5 A. No. At least from the information that I have seen,
6 the majority of children have visited McDonald's over a
7 year's period of time. Some visit more often than others.
8 I do not remember the exact figure, but I think it is about
9 20 times a year is the average visit for a child.
10
11 Q. Are you saying that the majority of American children visit
12 McDonald's 20 times a year?
13 A. I think it is the average.
14
15 MR. JUSTICE BELL: He said the majority of American children
16 have visited McDonald's; the average number of visits for a
17 child would be 20. You have to keep them apart. You
18 cannot then say that the majority of American children
19 visit 20 times a year, because that does not logically
20 follow.
21
22 MR. MORRIS: What is the average -- what does that represent?
23 A. It represents all the children in America; and if you
24 divide that by the number of visits that children maintain
25 going to McDonald's, you get an arithmetic division of 20.
26 If you put the entire child population and the number of
27 people who are part of that population, and you divided it
28 into the number of visits that children go to McDonald's
29 over a year's period of time, you get approximately --
30 again, I may be a little bit off here -- but approximately
31 20.
32
33 Q. So some children are visiting every week and some children
34 are visiting once a year?
35 A. Absolutely.
36
37 MS. STEEL: Do you know Al Golin, or have you ever met him?
38 A. Yes, I have.
39
40 Q. Do you know whether he had worked out some statistics for
41 McDonald's which said that children under seven years old
42 ate 1.7 hamburgers per week; ages seven to 13 ate
43 6.2 hamburgers a week; 13 to 38, 5.2 hamburgers a week;
44 30 to 35 ate 3.3; 35 to 60 ate 2.6; and age 60 ate 1.3
45 per week?
46 A. No. I have never seen a survey from Al Golin.
47
48 Q. Do you think that would be a thing he might be likely to
49 have said or a reasonable thing to have said?
50 A. Well, again, he was responsible for -- and still is, to
51 some degree -- some public relations. He may have worked
52 out some statistics, but I am not aware of those
53 statistics. I am not sure in what context they were given,
54 if they were given.
55
56 MR. MORRIS: Again, those figures are from page 102 in "Big
57 Mac".
58
59 MR. JUSTICE BELL: What is the point of saying that,
60 Mr. Morris?
