Day 258 - 07 Jun 96 - Page 13


     
     1        position in 1990, '91, may be based on a previous year's
     2        survey, or something, was that the average number of visits
     3        by heavy users was something like 135 for lunch and dinner
     4        ordering?
     5        A.  Sure.
     6
     7   Q.   You would accept that?
     8        A.  According to this, yes.
     9
    10   Q.   Yes.  Obviously, some would visit with less frequency and
    11        some would visit more, but the average for a heavy user was
    12        13 a times per year, nearly three times a week?
    13        A.  Yes, that is correct.
    14
    15   Q.   Right.  The heavy use in the States, as we saw, was 27 per
    16        cent of their customers, in America that is 27 per cent.
    17        Of that, would that be 27 per cent of the 30 million people
    18        a day that are visiting stores or 27 per cent of the
    19        overall customer base, which is the criteria you were using
    20        when you were looking at the figures, which was something
    21        like, I think, 38 per cent of the population or something
    22        here?
    23        A.  Yes, I mean, I have no idea.  I have no expertise on
    24        where US numbers are derived from, but they would be
    25        talking about customer visits rather than customers.  Even
    26        though the text says 'customers', I think what they mean is
    27        'customer visits'.  So.
    28
    29   Q.   It is 77 per cent of all customer visits, but 27 per cent
    30        of our customers?
    31        A.  Sorry?
    32
    33   Q.   Is that--
    34
    35   MR. JUSTICE BELL:  I will assume, unless someone points out it
    36        is quite wrong, these figures for the 1990 to 1991 manual
    37        must have been taken from figures obtained for a specific
    38        year, not necessarily to the 1st December year, quite
    39        possibly around the time of the publication of the leaflet
    40        complained of, and in the specimen period they found out
    41        that 27 per cent of people who went to a McDonald's
    42        qualified in that year, qualified as users, and generated
    43        about 77 per cent of all the visits in that year, because
    44        they are all annual.  Maybe they are for a short period
    45        than annualised are, but that is what McDonald's themselves
    46        are saying?
    47
    48   MR. MORRIS:  Yes.  So, if your customer base over a year in this
    49        country is something like 38 per cent, I think -- do you
    50        remember when we were looking at those figures in AF3, the 
    51        second page, you worked out that something like your 
    52        customer base was 21 million? 
    53        A.  Yes.
    54
    55   Q.   Out of a population of 56 million and I think, unless I am
    56        sadly mistaken, that something like 38 per cent of the
    57        population was indeed your customer base in that year?
    58        A.  Yes.
    59
    60   Q.   In America would you expect that to be higher, is

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