Tobacco Documents Online

856 320 5 i0 15 2O 25 answer to. you on page~twenty-f-ive .(25):~of-that discovery. Me IRVING: Would you mind the witness looking at it while you read it? Me BAKER: Not at all. Q- Starting at approximately line ten (i0). it out loud, please, Mr. Hoult? A- Would you like.me to read it? Q- Yes. A- This is line ten (I0), beginning "while trying..." Q- Yes. A- "While trying to narrow it a little bit, would it be fair to say that in the last few years this brand, Vantage, has been positioned in the concerned segment market, concerned about health? A- As defined by those segmentation studies, where a group of people on the last occasion did fall into that category in terms of their responses to those attitude scales, I would say yes, you probably would have a greater instance of that segment than say you would have in the Export family." Could you read AUDIOTRANSCRIPT, Oivisioo a~ Pierre Vilaire

857 321 i0 15 2O 25 Continue, please. "Q- But.when you position an advertisement or a series of advertisements into a segment of the market, you are targeting that segment, aren't you? A- Yes. Q- So if Vantage is positioned in the concerned segment of the market, you are targeting the concerned segment of the market by your advertising, are you not? You seek to attract those people to your brand who are concerned? A- Well, that is if we are targeting that particular segment. Q- Correct. A- If we are. Q- If you are. A- And I can't say that we were in the case of Van... I can't say that we were, in the case of Vantage,. over the last couple of years. Segmentation takes different forms. You can have different -- you can have brand segmentation which brands cluster together. Q- Yes. A- You can have demographic segmentation and AUDIOTRANSCRIPT, Division de Pierre Vilolr, & Associ4s kt@e

858 322 5 i0 15 20 A- 25 Q- you.can also have,-as we discussed, attitudinal segmentation. Q- I see. A- I'm simply telling you that whatever segmentation system was used for Vantage, yes, in my judgment you would have more of those people expressing those attitudes than another family of cigarettes." I'll shorten it for you, Mr. Hoult. If you'd now be good enough to turn to the middle of page twenty-seven And I'll read the question to you. Line twelve (27). (12): "In an analysis by your own people the recent family segmentation indicates that Vantage has been positioned in the concerned segment? A- Yes. Q- Concerned about what, Mr. Hoult? A- The concerned segment is a segment that is concerned about health as defined by the responses to-those attitude- statements. Q- Thank you." Now, Mr. Hoult, is it still your testimony today that your company never targets concerned people? Yes, it is. Okay. AUDIOTRANSCRIPT, Division de Pierre Vilalre & Asso¢ie, Ll~e

859 323 i0 15 2O 25 Om AD Could I~-elaborate. on-the response, because that simply describes a-segment that concerns smokers. You asked me specifically if we targeted, and my answer is no. What other kinds of groups does your company target? We have gone through the segmentation and I'll repeat some of those -- some of those that we discussed this morning. Women, men? Yes. M'hm. Age bracketed people? Yes. M'hm. Smarter? No, we don't target smarter people, though some of our consumers consider themselves smarter, as reflected again by their attitudes and beliefs about themselves. More highly educated as opposed to less educated? Yes, that we would -- that would be part of, generally speaking, socio-economic, a much broader group than education. When the company positions-brands, Mr. Hoult, does it try to stress attributes of the brands or the people who they seek -- whose loyalty they seek to obtain by their advertising? It does both. Brand attributes are selected, a) which we believe present a competitive advantage to us over AUDIOTRANSCRIPT, Division de Pierre Vila]re

860 324 5 Q- A- 15 Q- A- 20 Q- A- Q- A- 25 other brands, bub-obviouslF the attributes that you select to,advertise and to focus upon are those attributes that you believe that your target group wants. Could you give the Court an example of some of these attributes? Well, a simple example would be the brand Export where we focus almost entirely upon the smoking qualities of the brand, generally expressed as satisfaction, fullness of flavour and so forth. How about masculinity for Export? Yes, well... Is that an attribute? It's an attribute of our smokers, a very strong attribute. M'hm. And that would be reflected in the tone of our advertising, which would tend to be more masculine than feminine and the situations that we would choose would be masculine-type situations more than feminine. And would independence be another attribute of the... Yes. ...of the advertising of Export "A"? Well, we know from our segmentation studies that that is how the brand has been traditionally seen, as a brand AUDIOTRANSCRIPT, Division de Pierre Vilolre & Associ4s L~e

861 325 i0 Q- A- 15 Q- 20 A- 25 for independent---people,, ands. they. like .to see themselves that way. ~And-~much~of.. our..historic advertising has underscored that aspect. And is adventure... Yes. ...one of the attributes of that brand? Yes. The brand and the people who smoke it? Yes. M'hm. And qualities of.,natural leadership, is that one of the attributes of the smoker of Export "A" as you understand it from your very considerable research? I don't particularly recall -- recall that. Certainly as a brand we would position it as a leading brand, a leadership brand in Canada, but it would not be one -- to my recollection, not one of the qualities that the smokers saw in themselves. Does the company link concepts to brands as opposed to simply attributes that we have been discussing? With a new brand, a new brand in itself, at-least we try to ensure that it is a total concept as a brand, representing, for example, some of the qualities that you just described. An advertising concept is a very large, we like to think, a very large idea. And that large idea would be AUDIOTRANSCRIPT, Division de Pierre Vilaire & AssociEs LIEe

862 326 i0 15 20 25 translated into a specific-campaign~ Q- For example, would light be a. concept that you would associate with a brand? A- Would light? Q- Light, you know, lightness? A- Yes, light as a light extension? Yes, it would be a concept. Certainly, in recent years in the Canadian market, the move to light cigarettes has been sufficiently .... THE COURT: I'm trying to figure out what the hell you were saying. You're talking about light cigarettes. Me BAKER: Q- Now, the attributes. Are these things that you assume your potential customer or your existing customer will Am QN Am find attractive in respect of that brand? We would hope that it would go further than assume. In other words, one reason why we do so many pieces of research is to find out what our consumers want and what our competitive smokers want and attempt, a) to give it to them, and b) to communicate that we're giving it. So the object of the exercise for you then, as a marketer, is to get them to identify with the brand through those attributes; is that not correct? That's a very important part of marketing. AUDIOTRANSCRIPT, Division de Pierre Viialre & Associ~s Lt~e

863 327 i0 15 20 25 M'hm. -The brandhas, an attribute,-.the.consumer has an attribute, you match the consumer to the brand through the attribute; is that not correct? I think it can be expressed more simply by saying you determine what the consumer wants are ... And you give it. ...and you attempt to provide it. M'hm. What do you mean, or what is meant in your company's documents, when we read the expression: "Copy Objective,"~ Mr. Hoult? Copy referred historically to that which is written on the advertising, "copy." More recently, in the last few years, it has been taken to mean the whole of the advertising message, which would include the visuals. So a copy objective is the communication objective that you have in developing and putting forth an advertisement: what are you trying to achieve by means of that ad? M'hm. And then "copy testing" of course is? Would be testingthat.particular communication element in that particular ad. Does your research disclose, Mr. Hoult, that from time to time people other than those in the specified target groups find the ads sufficiently enticing to be attracted to that brand? AUDIOTRANSCRIPT, Division de Pierre V;toire & Associgs Ll4e

864 328 i0 15 20 25 Qm Well, when we begin a research program,.~.obviously, the research is much more broadly based, as we saw this afternoon, than your final target. And an ideal research program would narrow in until finally you define your age group and your sex targets and so forth. But, yes, the research does indicate, a) whether you've achieved your goals in the target group, and the degree of appeal in the groups that are in proximity to that group, whether it be age or geography or whatever. So. the answer is that it.goes beyond the specified target group to those in proximity to it; is that correct? Well, I thought your question was: does your research ever tell you? That the ads have attracted people other than those in the target group? Yes. And the answer is... And the answer... ...those in proximity thereto? Yes. Correct. So then, your advertising in respect of say: eighteen (18) to twenty-four (24) year olds might very well attract fifteen (15), sixteen (16), seventeen (17) year olds to it, would it not? AUDIOTRANSCRIPT, D~,,i~o,~ ~ Pie~e Vilo;~ & A~,o~i~, h~'e

865 329 Au 5 i0 Q- 15 A- 2O 25 Well, as.I~ve said, we had no information~because we have never.done any market research but, yes, it would be surprising if people who were fifteen (15) to eighteen (18) year old didn't see the advertising and, of course, seeing the advertising, they would get something out of it, they would have some comprehension, yes. In the same way that a group aged twenty-five (25) to thirty (30) would see the advertising and get some comprehension and get some message out of it. So the fifteen (15) and.sixteen (16) and seventeen (17) year olds might have the same attributes, to some extent, that those eighteen (18), nineteen (19) and twenty (20) year olds had that you were trying to target by using attributes in respect of the brand, and thereby find the brand and the advertising enticing? Well, you're being very specific when you talk about specific ages: eighteen (18), nineteen (19). We never think in those terms, as I said this afternoon. We divide the market generally into four (4) very large age groups, eighteen to twenty-four (18-24), twenty-four to thirty-five (24-35), thirty-five to fifty (35-50) and so forth. So we would never, and I don't think any social scientist would ever compare an individual age like nineteen (19) to an age like twenty-one (21). But I would say this, given the large differences that exist AUDIOTRANSCRIPT, o;,,i,lo,~ de Pierre Vilalre & Associ~s Ltge