Tobacco Documents Online

866 330 i0 15 2O 25 Om in the:twenties.~(20s),~:between people in their early twenties (20s) and late twenties (20s), I would not necessarily believe that people under eighteen (18) had the same beliefs or attitudes at all. Or aspirations? Not at all. So it's your testimony, then, that you wouldn't think that a sixteen (16) or seventeen (17) year old might have the same aspiration as an eighteen (18) or nineteen (19) year old? He might, but I would say he would not on the basis of the research findings that we have for older age groups and their differences. I see. Why would it be, Mr. Hoult, if your testimony is that you would be surprised if people in the younger groups didn't find the advertising interesting... I didn't say that. ...and perhaps an enticement -- I thought you did. I said they would see it and get something out of it. And get something out of it. Get some communication out of it. And why wouldn't your company bother to talk to those people? We do not market to people under eighteen (18) years, therefore we do not get information about people under AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associ~s L,~e

867 331 i0 15 2O 25 Ow eighteen (18) years. Isn't it-important-to you to know who's smoking your cigarettes? It's very important to find out who's smoking our cigarettes, but we define our smoking target as adults, aged eighteen (18) and over. I'm not talking about targets now, I'm talking about people who are actually smoking your cigarettes. Don't you distinguish between smokers and targets? Yes, we do. But we do not market to people under eighteen (18) years. I've heard you say that many times, Mr. Hoult, but I'm now talking to you about people who are actually in the smoking population of this country. You know that large numbers of children smoke, fourteen (14) year olds, fifteen (15) year olds, sixteen (16) year olds, seventeen (17) year olds; people who you say you do not market to. Correct. Having said that, however, you know that they smoke. Yes, they do. And you know that they smoke in very serious numbers; don't you? I do not know that, but I do, of course, know that they smoke. AUDIOTRANSCRIPT, Division de Pi,rre Vil~ire & A$,o(:ie, Lt~e

868 332 5 i0 15 2O 25 Q- You do not know that? A- It's a very... Me IRVING: My Lord, may I just, before we go any further, ask if Mr. Baker would be so good as to let the witness finish his answer before he puts another question as he did this time. Me BAKER: I'll try and restrain myself, Mr .... Q- Question: you do.not know that? A- I don't know what you mean by serious numbers. I don't know whether you're talking about individuals or amount smoked. Q- More than a few -- more than a few percent of the population. Me IRVING: My Lord, my friend has just done it again. Could we please let the witness finish his answer before we have another question? A- We have no information.in our company, neither I nor anybody in our company has ever sought information on people under eighteen (18) years of age and their smoking habits. Therefore, I cannot speculate on what you mean by serious numbers. I do know from my own observation, of course, that people under eighteen (18) AUDIOTRANSCRIPT, Division de Pierre Vilalre

869 333 i0 15 2O 25 years smoke. I simply repeat: we do not market to them, neither do we collect information. So anything that I would say in terms of how many smoke or how many they do smoke would be pure speculation on my part. Me BAKER: Q- Do I take it from your answer, or series of answers, that you as a company do not wish children under eighteen (18) to smoke? A- You do. That is correct. Q- M'hm. Could you explain to the Court how you could perhaps draw a magic curtain around the advertising that your company does so the children won't be exposed to it? We can't draw a magic curtain around our advertising. As I've said earlier, advertising is exposed to most people in Canada, and by various means, and we know what they are. I can only tell you that we make diligent efforts to ensure that our media selection is in magazines which.are directed towards our target, that our advertising message and our brand positions are developed according to market research, are always carried out among adults, and that we abide very willingly with the CTMC code in order to limit such exposure. But there is no way that we can draw a magic Am AUDIOTRANSCRIPT, Division de Pierre Vilalre & Associ~s L~'~e

870 334 5 i0 15 2O 25 curtain around. Now, when you say the code, are you referring perhaps to the age of models? I'm referring both to the age of the models and in terms of where advertising is placed. One aspect of the code, for example, covered where outdoor advertising should be placed. It should not be placed within a certain distance from schools and we abided by that, as I say, very willingly. It is part of our corporate philosophy anyway. Me BAKER: Qm Est-ce que je peux voir, monsieur le greffier, les photographies? I'm showing you, Mr. Hoult, Exhibit RJR-9. It is an advertisement for Tempo. The written words at the bottom of the page are: "New time - New taste" In the center of the advertisement or the bottom third, you see a pack of cigarettes with a cigarette across it obliquely, and most of the document is a photograph of two (2) people. Would you describe these people as young people? I'd describe them as young adults. As young adults. And what are the major colors in this photograph, Mr. Hoult? The pastel colors of pink, blue and yellow. AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associes

871 335 I0 15 2O 25 .Q.- Ou Hm, hm~ Now, does.my memory serve me-correctly and did I hear you tell the Court-that the object of Tempo was to compete against duMaurier and Player's, was it? It was to compete among young adults with these two (2) brands that were very strongly positioned in the market. How would you describe the present consumer? When was this series of ads done? Do you remember, Mr. Hoult? I can't remember when they were done, but they were done prior to the launch of the brand, I would judge some time.in the middle of nineteen eighty-five (1985). I see. In the mid-eighties. Would it be fair to describe the typical duMaurier smoker as urbane, sophisticated, socially upscale? Would you accept that as a characterization of that group? That is the image of the brand, yes. Hm, hm. Now I put it to you, Mr. Hoult, that this advertisement that I have in my hand, RJR-9, with its pastel colors and two (2) youngsters with punk haircuts, is dramatically different from what you would expect to find as a duMaurier smoker at the same time, same period of time, in the mid-nineteen eighties (1980)? Perhaps you could now re-analyze that document for the Court and tell us how it is that you were seeking to obtain switchers, for example, of the duMaurier brand with that kind of advertisement? AUDIOTRANSCRIPT, Division de Pierre Vilolr, & Associ4s Ll4e

872 336 i0 15 2O 25 am Am Om Well, firstly you~described.them as.having punk haircuts. I don't accept that at all. I see. These are... Those are not punk haircuts. How would you describe it? and slicked to the side. traditional duMaurier smoker, would you agree with me? I would certainly say that the image of duMaurier would not fit this, which is the major part of -- the major thrust of your question. I'd like to answer it and say the reason that young adults smoke the brands Export, Player's and duMaurier -- and in our case, the competitive brands of course were the two (2) latter -- was that there was not, until we attempted it, a brand specifically and overtly directed towards young adults and this is what we were trying to do. All of those brands were positioned fairly traditionally, but I remind you that when we talked about duMaurier being a major competitor, it was because duMaurier was the most successful brand in this mid-tar segment of brands, which was segment 4. Now that's the tar segmentation. Yes. I'm talking about people who smoke the cigarettes in those segments. They look sort of slicked up I mean, that's not the AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associ~s LtCe

873 337 10 15 2O 25 A - The young-adults--who,, in. that age-group who-smoke, young adults age eighteen(18) to twenty-four (24), smoked primarily the brands Export, Player's and duMaurier. And one reason for that was that these are the three (3) biggest brands in the market. And we specifically set out to communicate that this was a brand for young adults. That was our explicit objective. Q - And is it your testimony -- would it be your testimony that the typical Craven "A" smoker, in the mid-nineteen eighties, was also~a young adult? Is that what your research discloses about the Craven "A" smoker in the mid-nineteen eighties, Mr. Hoult? A - No. All the brands that we've talked about, and Craven "A" too, have an age distribution that goes across a fairly wide band. Q - I thought that the Craven "A," the characterization of the Craven "A" smoker was to older people. Me IRVING: My Lord, the witness was not finished answering the question again or was just about to... A - When I describe brands as having an older age profile or a younger age profile, you must understand that I'm talking about where the center of gravity is for that particular brand. Craven is a somewhat older profile, but there are still many thousands of young adults who AUDIOTRANSCRIPT, Division de Pierre Vilolre & A.~so¢i~, Ll~e

874 338 i0 15 2O 25 smoke.Craven~ It.'s~..just.that. they-have more, of their total profile, they are more older smokers than other brands. Export has a bi-polar image. It has a fair share, a very strong share of young adult smokers but also a very large share of smokers in their forties. So I'm not -- there is no such thing as a brand that is only for young adults or only for older people in Canada. We were trying to position this specifically as a brand for eighteen (18) to twenty-four (24) year-old. M'hm. Now you described a brand as having a center of gravity. Is that correct? They were my terms. Yes, your terms. Now, the center of gravity of Craven "A" is considerably older than eighteen (18) to twenty-four (24), isn't it? Yes. Right. But it does have its share of smokers in that younger age group. Well, I'm sure every brand does, Mr. Hoult. Yes, that's what I'm trying to say. Now, is it your testimony to the Court that your company launched this Tempo brand, you say or you testify that you were trying to fill the -- or go after the duMaurier AUDIOTRANSCRIPT, Division de P~erre Vilaire & AssociSs Lt~e

875 339 5 A - A - i0 15 Q- 20 A - Q- A - 25 and Craven "A" smoker~--but-that.-the~center of gravity of one (I) of the two~(2) brands was significantly older than that which you hoped to attempt to become a Tempo smoker? We saw... Does that make marketing sense? Yes. We saw an opportunity in the Canadian market, as expressed by the market research that we've described, the needs and.beliefs of young adult smokers for a brand that would be recognizable by them as a brand for them rather than for people in older age groups. The fact that the brand didn't succeed indicates that we either did it wrong or we were wrong. But, nevertheless, that was the plan. And as you go through the research which is in the exhibit, you will see a very strong interest in this concept by people aged eighteen (18) to twenty-four (24) years, hence the planned launch. You couldn't get them away from Craven "A". We couldn't. Or duMaurier, or Player's for that matter. Right. Could you explain to the Court why it is that when your company does use people in the advertisements, they're invariably attractive? Well it doesn't make so much sense to me to put ugly people in advertising. AUDIOTRANSCRIPT, Division de Pierre Vilc~ire & AssociEs Lt4e