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735 197 10 15 2O 25 AD very aggressive marketplace. So-those sorts.-of-funds--allocated for the first three (3) years of a new brand are disporportionately high and had we projected this out for ten (I0) years, that proportion would have diminished once the brand was established. Now, was third family targeted against any particular brand in the marketplace and, if so, is that what I see on page nineteen (19) of this? Yes. At the time of the writing of this plan, we looked very carefully at our competition and third family was particularly directed at the brand Craven, which was one of the brands of Rothmans, and against DuMaurier, perhaps the strongest brand in the segment; certainly the strongest brand in the segment which was an Imperial brand. So that looking at the strategic plan you will see, then, a general allocation by percentages of available resources as forecast over the next three (3) days, and we'll-come back to that plan, but I would like to go now, so the Court may have an immediate idea, and ask you, Mr. Hoult, in general terms, how much you have been spending or were spending on advertising prior to the ban, and I have ... Now, Mr. Hoult, I had asked you if you could have AUDIOTRANSCRIPT, Divisio~ d, Pi~rr~ Vilalr~ & As~o~i6s Lt~e

736 198 5 i0 15 2O 25 prepared a document which would show your total advertising and promotional spending,-.historically going from nineteen eighty-seven (1987) back to nineteen seventy-six (1976), with a breakdown, not in great detail, but a breakdown. Is this the document which... A- Yes, it is. Q- ..shows that? Can I have that marked, please, as RJR... THE COURT: 3. Me IRVING: 3. Q- Let's just take one (i) year, Mr. Hoult, and if you could just explain tO His Lordship what these figures represent? A- Which year would you... Q- I think we'll take nineteen eighty-seven (1987) and -- I see it's three fifteen (3H15), My Lord, if you were going to take the afternoon adjournment, as planned, I'll leave this until we come back. If not, I'll just carry on. THE COURT: We'll take a ten (i0) minute break. SHORT RECESS AUDIOTRANSCRIPT, Division de Pierre Vilalre &

737 199 i0 15 2O 25 Me IRVING: Q - Now, Mr..Hoult,.looking.at~RJR-3, let,s take..a single year -- it won't be necessary to do it for more than that -- take nineteen eighty-seven (1987). THE COURT: Q - Okay, are we dealing in -- I can't read the top of the page. A - Canadian dollars, My Lord. Q - Yes, Canadian. Me IRVING: Thousands of dollars. THE COURT: Thousands? Me IRVING: Yes. THE COURT: So I have to multiply the number by one thousand (i,000)? Me IRVING: Just add.three. (3) zeros. So that print advertising then is one point four (1.4) million dollars? Correct. And the signs are six point eight (6.8)? Correct. AUDIOTRANSCRIPT, Division de Pierre Vilc, ire& Assoc;4s Lt4e

738 200 i0 15 2O 25 Am Now, what is production? Production is.the cost. that.an..advertising agency and its printers incur in producing the advertisements, either in magazines, billboards or -- or for -- so that's the actual printing cost. All right. And agency fees, is that the ad agency? Yes, this is the fee that an advertising agency gets for giving you its service over the year, and that fee is based conventionally as a proportion of your total billings, your total advertising expenditures. Now, point of sale? Point of sale is that material which is used in the retail outlets. Conventionally, point of sale would be paper or cardboard. We have sponsorships, which you've already dealt with. What is research, first of all? Research, in this context, refers to marketing research, and that is the cost of carrying out our consumer studies of various sorts and it amounts to the fees which we pay. to our~market research agencies who. do ~this work for us. Finally, and by far the largest item, is retail. What is that? Retail is the sum total of all payments that you make to the retail trade, either in cash or in products, in AUDIOTRANSCRIPT, Division de Pierre Vilalre & Associ4s Lt4e

739 201 l0 15 20 25 order for you to, for example, put up a counter unit display-wher~e~you'.re,-say, having, a~specialoon Vantage, you will have a counter unit, you would pay for that. You also pay for the amount of space behind the counter typically, that you are buying to display your products. Now, in our case, as a company, we have sales cycles which each are six (6) weeks in length. And each sale cycle has a special program and you pay the retail trade for this. Q - Just follow His Lordship's pen a bit, Mr. Hoult, because His Lordship is trying to take notes as we go along, so try to keep the timing. THE COURT: No, numbers is okay. Me IRVING: Q - All right, so that, RJR-3, now... THE COURT: Q - I see that has increased a lot since nineteen seventy-six (1976) in the retail... A - Yes. Q - ... versus the rest of the... A - That is a very -- very marked phenomenon, not just in our business but, I think, in marketing generally, that as the power of the retail trade increases versus the manufacturer, the demands for the sorts of things I've AUDIOTRANSCRIPT, oi,,i~ioo d~ P~ Viloi~ & A,socie, Lt~e

740 202 l0 15 20 2S described. And in our particular case, with a very aggressive indust~ry, with brands fighting each other all of the time, it's a normal economic law of supply and demand. There's a limited amount of space that you can buy and the price has gone up, as you.., as you have pointed out. Me IRVING: Q - Now, Mr. Hoult, we have looked at a sort of general allocation of funds over a three (3) year period in the strategic plan, we have looked at the overall amounts you've been spending. I'd like now to come to the process by which an actual advertising budget gets put together within your company. Where does it start? A - The evaluation of the market is an ongoing process and that comes together, as I pointed out, in the strategic plan. And in the course of putting together a strategic plan, there are all sorts of people in the company who are making cases for priorities, spending and so forth. In a company like ours, which I described as a market-driven company, these demands are-coming from below by, essentially, the brand management group. These are -- there's a group of professionals, each of whom is responsible for a brand. Now, a professional has the responsibility of monitoring and evaluating the competitive brands to his AUDIOTRANSCRIPT, Di~i,ioo de Pierre Vilaire & Associgs Lt@e

741 203 io Q- A - 15 Q- A - 20 25 own brand all of the time, and that is the basis, the beginning of the.budgeting~process, the recommendations from brand management groups. Okay. So just to take an example, Mr. Hoult, you've mentioned the brand Export. So is there a brand manager for Export... Yes. ... in the company? Yes. And would there be a brand manager then for each of the other major brands as well? For all the major brand family, certainly. Some of the smaller ones would be combined. There would be a brand manager looking after three (3) or four (4) minor brands. But the major brands, yes. So let's -- starting with the brand manager and looking at the creation of an overall advertising budget, what is his role? Well, as I said, the preliminary role -- not the prime role --.but the preliminary role is to be.absolutely fully informed at all times of the current performance of his or her brands, the potential, is the growing brand steady, declining, and equally importantly, at all times knowing what the competitive situation is for the competitive brand that's fighting that particular brand AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associgs L,~e

742 204 5 i0 15 20 25 in the marketplace. With this ongoing knowledge and information, he or. she would be .essentially responsible for putting forward a proposal to the next layer of management to obtain the resources and funds to attain a certain goal, which that person would commit to: "Give me so much and I will deliver you so much in terms of share or volume." THE COURT: Q - Okay. He makes his proposal to who? A - Well, normally the brand manager would be making his proposal, at this time of the year, for the strategic plan, to the Marketing Vice-President, I think. The Marketing Vice-President would put together all of these individual plans and he or she would then make a very formal market plan submission to me, as I was, as the C.E.O. And I would be evaluating their recommendations, testing their commitments and ultimately one of my major responsibilities as the C.E.O. was to determine how resources should be allocated. Me IRVING: Q - Okay. Now, I'd like to come back to the brand manager for a moment, because you said that one of the brand manager's responsibilities was to look at the competition. And what is the brand manager looking at, Mr. Hoult? AUDIOTRANSCRIPT, Division de Pierre Viloire & Associ~s Llge

743 205 I0 15 2O 25 A m Firstly, he or she is looking at performance on a very frequent basis,.and the Neilsen performance .that I have referred to earlier which indicates for every brand in the market what its consumer offtake is, what its distribution is, whether it's growing and so forth, are of prime -- prime importance. Secondly, it's an evaluation of activity and this activity comes back to us or to him or her in the head office from all sorts of sources, two (2) of the most important sources being market research, which would be commissioned on a, for a major brand, almost on an ongoing basis, and secondly from our sales force which we regard as our first line of intelligence in terms of what is happening in the marketplace. Now, I'd like to go back just for a moment to Tab 1 in the book, My Lord, page twenty-one (21). It is entitled "Market Spending by Brand", and going down the left-hand column, there are your brands, Export, third family Vantage and so on, and underneath that I see Player's, Du Maurier,~Matin~e and-then. "Total, Imperial Tobacco". And then moving along to the right, there are some numbers under the heading "Measured Media Expenditure". What are these figures that you have here for, say Player's? Measured media is really an expression, a literal AUDIOTRANSCRIPT, Division de Pierre Viloire & Associ~s Lt6e

744 206 5 15 A - Q- A - 2O Q- A - 25 Q- expression of what it is. It's the media exposure that you can measure.. And all advertising agencies, at least ours, have a service whereby they are monitoring at all times what individual brands are spending and what particular exposures they have. So that's a very reliable measure. It's published data, also, which the advertising agencies have access to and you can very easily calculate, from where they are appearing, what they can spend, because the costs of what they do are in the public demand. They're... So when I... They're public costs. When I look along the line for Player's, am I seeing what your estimate is of what Player's has been spending? Yes. For advertising? That is advertising as on billboards, magazines, newspapers. That would not include areas that couldn't be measured, with the same degree of .accuracy, like in-store activity. Okay. Or sponsorships, that would not be included in those figures. All right. So there's one column, "Major Media AUDIOTRANSCRIPT, oi,,i,lo,~ d~ Pi,rre Vilc~i:, & Associes

745 207 i0 15 2O 25 Expenditure", and then next to that the column is entitled "Percentage Share of Voice". Would you tell the Court first what is share of voice, Mr. Hoult? A - Well, voice is a bit of marketing jargon, and voice really means how loudly are you shouting. So, the total voice is one hundred percent (100%) and the competition has fifty percent (50%) share of voice. It means that they have fifty percent (50%) of the presence of all messages going to the consumer at that particular time. So it's the share of total voice that the different brands have got. THE COURT: Q - I'm not sure I understand what you are saying. A - The total expenditure in the industry at any one time is called the total voice. Q - Okay. A - All cigarette advertising, all sponsorships, all other activity. And that is very much an estimate, and you might say the total expenditure in the year nineteen eighty~seven__(1987)~was of the_order, say, of one hundred million dollars ($i00,000,000.00). And if that were the case -- and I'm making it up for illustration -- our expenditure, if, say our expenditure was twenty million dollars ($20,000,000.00), we would have a twenty percent (20%) share of voice. AUDIOTRANSCRIPT, ~;,,~,;oo d, Pierre Vilaire & .~,$~oEie~ Li'~e

746 208 5 i0 15 20 25 Q - Okay. Me IRVING: Q - And is this your share of total advertising expenditure or total... Total marketing... ...in any category? Total marketing expenditure, because the advertising expenditure is very clear. You can measure that very accurately. Hm, hm. But the total spending does include things that you have to estimate, like point of sale activity, in-store activity, merchandising activity and, of course, sponsorship activity. And do I understand correctly then, Mr. Hoult, that your brand managers, in preparing their own budget requests, as it were, will monitor the amount of spending which they are able to measure for the brands which are competitive to theirs? Well, they.certainly.~wouold, because one of-those telling arguments for asking for a budget increase is to say: "Look, this competitive brand against my brand, Export, has doubled its expenditures last year, and I need to do the same if I'm to remain competitive" So it would be utilized that way and very important. ,4UDIOTR,,4NSCRIPT, Division de Pierre Vilalre & Associ4s Lt4e

747 209 i0 15 2O 25 Am And each brand manager then would do that, would Okay. he? Yes. And would do it in relation to the brands competitive... Yes. ... to this particular brand? Yes. So, in describing the process then, you have started with the brand manager and I think you said, in answer to a question from the Court, that the brand managers would report up to the Vice-President Marketing? Yes. So that person is getting the... That person would take all these parts, make some evaluation and modification himself, bring in his own input in terms of priorities, in terms of opportunities and finally the whole thing would be put together as a marketing plan which would be a part of the strategic plan. And I would evaluate that marketing plan alongside a manu,facturing.plan and alongside a sales plan and so forth. Now, as the -- at the time when you were the Chief Executive Officer, President, then you would be receiving through the Vice-President Marketing the combined efforts of all these brand managers? AUDIOTRANSCRIPT, Division de Pierre V;Io~re ~ Associ~s LtCe

748 210 I0 15 20 25 QD Am Qm Yes, I would. And would you just tell me again what .was,-in fact, your role during the time when you were C.E.O. in dealing with these forecasts, these requests? It can be summarized by saying it would be, a) an evaluator... Hm, hm. ... to determine the credibility, depending on the evidence put forth, of the proposal. Can you really grow this brand or have you really given up on this brand and so forth. I'm sorry, when you say: "Can you grow this brand", do you mean... Share. ... "Can you increase your share of market"? Yes. Yes, okay. Because, normally, such a commitment would be in parallel with a fairly large request for increased funds... So you would be the evaluator,.and having evaluated, it was finally my decision, my responsibility to allocate corporate resources accordingly. Hm, hm. And in reality now, and during the time you were the C.E.O., were you ever able to... AUDIOTRANSCRIPT, Division de Pierre Vilalre & Associ~s Ltge

749 211 5 i0 15 20 25 THE COURT: When you say.C .... Me IRVING: Chief Executive Officer, My Lord. THE COURT: Oh, Chief Executive Officer. Me IRVING: President. Q - Were you ever in a position to approve everything that was requested by all of your brand managers? A - No. Fairly typically, the total sum of that requested exceeded by far available resources. Always the problem was one of cutting and pruning and protecting those projects that you had a belief could succeed, but the demands always exceeded the resource supply. Q - Does the -- did the extent and nature, or the extent anyway, of competition relate at all to whether the overall market is in decline? A - No. The extent of competition had had -- has an effect only on. the distribution of share between-the different companies. Q - But when the overall market is declining, Mr. Hoult, does that make competition less severe or more? A - Oh, it makes it more severe, for two (2) reasons: a) there's a smaller pot, and therefore the slices are AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associgs Lt@e

750 212 10 15 2O 25 capability. THE COURT: Q - really fought for, and it's not insignificant that expenditure has increased very-dramatically over the last three (3) years and that's a company in a period when the industry has declined more severely than in the past. Secondly, and very importantly, with the industry decline, there has been an over-capacity of production And if you are... Do.you have -- I'm sorry, I missed -- I missed you -- have a smaller share to -- part to share and then you have what? A - And then the other side, in terms of costs, is the production over-capacity that currently exists in the Canadian market. Given the market decline, we have facilities and capabilities of producing significantly more cigarettes than the consumer is demanding. And when you have this situation your costs escalate very rapidly. Me IRVING: Q - Now going back to Tab 1 just for amoment, just to refer to the competitive situation, Mr. Hoult, would you look at page nineteen (19) of the strategic business plan? Looking at that second (2nd) paragraph on the page, is that a reference to the competitive situation you've just been describing? Down at the bottom of that AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associgs Ltee

751 213 i0 15 2O 25 paragraph. A - Yes. Yes,~it does.. It describes.the.competition between the companies and specifically the competition between two (2) very strong brands, Players and DuMaurier in this case. Q - Now, you spoke a few moments ago about ongoing research, Mr. Hoult, and I'd like you to look, if you would, at Tab 3 of the... THE COURT: Are you -- I'm sorry, Mr. Hoult -- Mr. Irving, are you going to put an exhibit number on this? Me IRVING: I will, My Lord, but I have one other exhibit which is not in here to put in and I thought that since we'll be spending virtually the rest of Mr. Hoult's evidence on this book afterwards, I'd wait and then we could number these consecutively. I thought it might be easier. THE COURT: Okay. Me IRVING: There's one more exhibit I'm going to put in. I'll give it to my friend at the end of the day today, so he has it, and then there won't be anything left except the book, and tomorrow we'll simply give consecutive numbers to these, simply. AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associgs tt4e

752 214 i0 15 2O 25 THE COURT: SO we are moving to Tab 3..now? Me IRVING: We are, just for the moment. Yes, My Lord. In view of the time, this will be the last subject today, I think, and I just wanted Mr. Hoult, not first with specific reference to this tab, but to tell the Court the kind of general research, market research that you carry out on a regular basis. A - On a regular basis, we carry out product testing, which is the monitoring of how the consumer sees our products versus the competition. And product testing involves giving the consumer the product and coming back a couple of days later and say: "Tell me what you thought of it" on rating scales. We carry out regularly image studies of our brands, again always versus the competition, what our strengths are, what their strengths are, what the weaknesses are and the opportunities. Of course, we have the Neilsen information on an ongoing:basis.and, we have ~many.specific studies which I know we'll get into -- you referred to them earlier -- on individual projects. But those are the sorts of basic monitoring studies that we do, and at periodic intervals, every one (i) or two (2) years, we will carry out what is described as a total market evaluation, AUDIOTRANSCRIPT, Division de Pier,, Vilaire & Associ~s U~e

753 215 i0 15 20 25 segmentation study, where you will look at your market as a totality, and divide it into segments, so you~can focus on each individual segment and understand -- understand more about it. And you will monitor how the market has changed over time, like comparing one segmentation study with the past studies. Now, we've already looked in Tab 1 at the seven (7) segments of the marketing, so far as they relate to cigarettes, segment 1 being the highest tar and nicotine and so on. Would you explain to the Court the other kinds of market segmentation which exist? A - Well, the first, as you rightly described, is segmenting the products. Essentially, it's as simple as sorting the products into those products against which they're competing. The other major method of segmentation, which is a little newer in the market, it does require, you know, certain techniques that have been borrowed from the Social Sciences, is consumer segmentation. And in consumer segmentation, you will look at your total universal.smokers~and by means of a series of attitudinal questions, behavioural questions, demographic questions, you will, using various statistical techniques, group the smokers into segments. THE COURT: Q - Attitude, behavior and...? AUDIOTRANSCRIPT, Division de Pierre Vil(}ire & Associ~s Ll4e

754 216 I0 15 2O 25 Demographics. Social class, age, sex and so forth. I would like_~to.just..add-one.more.word about.the ~so-called consumer classification. This can be done in several ways, but two (2) of the most common are just taking them as they are, without regard to their smoking behavior and seeing what they are like as general consumers. And these are very general questions of the sort that relate to consumer behaviour, like: "I like to experiment a lot in the products I buy". And the other type of consumer classification and segmentation is where you will take particular cigarette or tobacco dimensions and you will classify them as cigarette smokers more specifically than consumers. So that's very refined, very tight, and the other is more general. Me IRVING: Q - Now, if we look at Tab 3 now, Mr. Hoult, which is called "Family Segmentation -- Segment Descriptor Study." And my friends won't mind my saying, My Lord, since they have -- havethis~and.have the other document, that this comes from a survey which runs to some three hundred and fifty (350) pages which we don't intend to put to the Court ... Me BAKER: What number Exhibit was it? AUDIOTRANSCRIPT, D~,~oo cle Pierre V~lalre & Assoc~s Ll@e

755 217 5 i0 15 2O 25 Me IRVING: I'ii give you the..number, afterwards. Me BAKER: I would like -- excuse me, My Lord. We've been operating for many, many months now with a variety of documents under a number which was indexed to their index number. And -- no, no, those are page numbers, Mr. Irving. What number was it on the index that you gave us, so we can locate the three hundred (300) page document that you're referring to? Me IRVING: Well, am I not... Me BAKER: You're telling the Court that you've taken this out of a larger document. Me IRVING: No, no, no. No, no, no. I say -- just a moment, I'll... Q- This study, Mr. Hoult, if I understand it correctly, was made on the basis of another and much longer survey. A- This summary. Q- Yes, this is a summary. A- Yes. Q- Now, just turning to the second page of it, the pages -- the numbering here, My Lord, is to be found in the right AUDIOTRANSCRIPT, Division de Pierre ViJaire & A,so¢;~s Lt4,

756- 218 i0 15 2O 25 hand corner and it's a sort of code -- coded numbers which were used.in providing.documents to. my.friends for the Attorney General. Otherwise, the numbers, there are no numbers. And I see in that little box used three approaches to segment the market. Are those some of the kinds of segmentation we've just been discussing? A- These were the segmentation methodology I've just discussed, yes. The first were cigarettes, how people see cigarettes; that's called family segmentation. How the brands, the family brands of cigarettes grouped together. Second, is the consumer classification, according to how their attitudes to smoking emerged. Q- M'hm. A- And finally, more broadly based, their groupings as consumers. Q- Going on then to the next page, brand family segmentation, I understand it then, that this looked at sixteen (16).different brand families? A- Correct. Q- If you go to the next page could you just explain to the Court what this chart is? Me BAKER: Excuse me, My Lord, I am loathe to interrupt my friend, AUDIOTRANSCRIPT, Division de Pierre Vileire & As,o¢I4, Ll4e

757 219 5 I0 15 20 25 but there is no reason why he shouldn't provide us with the number which, we have been using .for eight (8) months for this Exhibit. I don't know what it is. He's just given us a document. Somewhere in this book, this index that we were provided seven (7) or eight (8) or nine (9) months ago, this document is described. And surely to goodness somebody in this team knows which number it relates to. He's just put it in a new bound volume without reference to any number. Me IRVING: Well, my friend has the entire document in front of him, My Lord, but I'll give you the number. Me BAKER: That's the... Me IRVING: 004 on your list. So saith our computer! Me BAKER: Thank you. Me IRVING: So says our computer, which has to be right. Me BAKER: Wait a minute... Me IRVING: It's the same document, Mr. Baker, so. AUDIOTRANSCRIPT, Divi,ion de Pierre Milaire & Associ~s LtGe

758 220 i0 15 2O 25 Me BAKER: Yes, I know. Me IRVING: And we won't be finished with it at the adjournment for today, so why don't I just go on? My Lord, I can assure my friend he has the document. If he wants another identification... Me BAKER: I wasn't suggest -- no, please don't misunderstand me, Mr. Irving, I'm not suggesting I didn't have the document. I simply wanted to be able to locate my own copy which has a number; it's now been done. Thank you. THE COURT: And you have your notes on it and you're happy? Me IRVING: Okay. THE COURT: Good. Me BAKER: More than-happy,.My Lord. THE COURT: I understand that. Me IRVING: Q- Now, Mr. Hoult, could you give the Judge an idea of what this rather strange looking chart is? AUDIOTRANSCRIPT, Di,,i,~o~ d~ ~i~.~ Viloi.~ & A,,o~i~, L,~

759 221 I0 15 2O 25 A- Yes. In very broad... THE COURT: Twenty-two seventy-two (2272). Me IRVING: An Twenty-two seventy-two (2272). It's about the fourth page. It looks vaguely astrological. In the broadest of terms the individual Respondents in this study would be asked to evaluate brands on different dimensions. M'hm. Both in terms of imagery and what the products were like and what other products they competed with and so forth. All of these dimensions would then be subject to a technique which is called factor-analysis. It doesn't really matter what that is, it's just a scientific or a statistical tool, which is utilized to find like with like. And as a result of this particular analysis, as it says in the title here, what emerged were five (5) discrete and different family segments with very little overlap andeach segment-is defined-by the brands within it. Okay. Well, just looking on the right-hand top quadrant, should I take from that then, that Accord -- do that, My Lord, I'm in the top right there -- Accord, Medallion... AUDIOTRANSCRIPT, Division de P~erre Vilalre & Asso¢i~s t,6,

760 222 5 i0 15 2O 25 THE COURT: Smokers Qf Accord, you would, find more. smokers of Accord, Medallion, Vantage and Viscount. These are the persons who smoke Accord would be the same type of persons that would smoke Viscount or Vantage? A- Well, they have the same -- the brands represent some similarity. And the conclusion that one would draw from this, and it's overly simplified, is to say: hey, these brands are competitive. These are the brands that are competing with each other. Me IRVING: Q- That's what I was coming to, Mr. Hoult. So, each of the brands within one of those little dotted circles, then, is generally competitive with the other brands within the same circle? A- Correct, yes. And you will see, and it's not unimportant for us, that DuMaurier is a segment... THE COURT: Is all alone by itself. A- ...in its own right and.a very strong brand, and that was one of the reasons for our going into that fourth (4th) segment. And that was the brand that we were aiming to compete with. Me IRVING: Q- All right. And then on the next page there's the share AUDIOTRANSCRIPT, Division de Pierre Vilalre & Associes Lt4e

761 223 i0 15 2O Am of market by segment. Yes, that's a_fairlZ simple pie,chart.. You see.that.the shares of market the segment -- the various segments have and the brands that are making up that share. Now, we're going to come next, really it is just the next page, which is entitled RJR MI representation within the family segment, and we're almost at four o'clock (4H00), Mr. Hoult. My Lord, I think it's going to take a few minutes to go through this. I would be quite happy to start, but if we do have to stop because of the election, perhaps this would be a convenient moment, so we'll get all of this together first thing in the morning. We'd only get done with masculine and we'd be -- which is the first segment, and we'd be stuck in the middle of the road at the adjournment. THE COURT: We'll adjourn. Anyways, it's four o'clock (4H00) now. ADJOURNMENT AUDIOTRANSCRIPT, Division de Pierre Vilo;re & Associ~s Lt~e