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1210 676 i0 15 20 25 Qm Am Am allocating the resources to them and seeing they're conducted correctly. And why is it that Imperial engages in sponsorship of sporting activities or cultural events? Well, it's our view that sponsorship is a form of communication, albeit expensive and limited, but it can add some credentials to a brand's image. We think specifically those of quality or perhaps popularity through being bigness -- through bigness through being, you know, one (i) of the big brands. As an example, one would expect a brand or company that sponsors a world class event with a very large prize person, world class competitors, is a fairly large company and there's, I think, some credibility to that. There's corporate image to be considered, there's a number of reasons why sponsorships are chosen. And brand sponsorships, the kind of brand -- sponsorship that you did until the end of eighty-eight ('88), that brand sponsorship does it contribute to the image of the brand? Yes, I believe it does. And... It's difficult to evaluate but in the same sense, when you say brand, it's brand name or trademark and, in fact, it's a trademark more than brand and there's a AUDIOTRANSCRIPT, Division de Pi .... Viloi~, & .:-.ssoci¢s U~'e

1211 677 5 A- 15 Q- 2O A- 25 Q- difference when you consider there's a large variety of brands but it's -- it contributes to the trademark's image in a manner, I think, that I explained in that it's a quality brand or it's from a quality company that concerns itself about the community. I think people view it as returning something to the community. It's -- it's corporate image and in a sense, people view trademark as companies. So, in that sense, we think there's positive images but they're very -- they're very quality oriented and very broad. What do you mean by that -- "very broad"? Well, you couldn't, I don't think, select a sponsorship that would tell a consumer that you have a product differential or a new package, you don't use the package, it's just the name. So a sponsorship can't do specific communication on the product or lifestyle image, for example, perhaps a little bit. So it's more an aura around a trademark of quality and class. And to use your word, Mr. Brown, specific, the kind of specific message that you want to give to your consumer, how can you give that specific message? Well, as we have talked about this afternoon, it would be through, particularly, media advertising, a form of communications or in-store advertising. And what are the kinds of things you can do with AUDIOTRANSCRIPT, Division de Pierre Vilaire & Associes bee

1212 678 5 i0 15 2O 25 Am advertising, media advertising, in-store advertising that you cannot do with a sponsorship? Well, as I say, you cannot through a sponsorship, at least one that I can envision, would tell a consumer that you've changed your product or to tell a consumer what a new product is like if it's an introduction. Or you can't tell them why you've changed the package or, to a lesser degree, what kind of people are perceived to be using your product. There's very few messages ~that sponsorship can communicate. It is very, very broad and very -- it takes a long time and a lot of money to establish, I might add. So it's very inflexible in that regard. Me POTTER: My Lord, I'm about -- about to embark on a subject which will last considerably longer than the five (5) or six (6) minutes remaining. I'm in your hands. I can begin or leave it until tomorrow. THE COURT: What do you want to embark on? Me POTTER: Pardon me? THE COURT: What do you want to embark on? AUDIOTRANSCRIPT, Division de PI .... Vilalre & A .... i~s bee

1213 679 i0 Me POTTER: I want to go through the mechanics of a whole advertising campaign, and how it begins and where it leads to and what can be done with it. Me BAKER: Are you going to be the whole day with Mr. Brown? Me POTTER: Monday. the day on Monday. No, I think we should be over before the end of Thank you, My Lord. AND FURTHER DEPONENT SAITH NOT. AUDIOTRANSCRIPT, Division de Pi .... Vilair~ & A .... i~s Ll~e

1214 I, the undersigned, SYLVIANE SAVO, recording monitor, swear that I have personally conducted the recording of the preceding evidence and representations, verifying continually the quality of said recording, that I have prepared minutes of this hearing with due attention and that in no case was the equipment used defective. AND I HAVE SIGNED : SYLVIANE SAVO I, the undersigned; JANE WEAVER, proof reader, swear that the predecing pages are and contain the faithful and accurate transcription of the English recording. AND I HAVE SIGNED : JANE WEAVER Je, soussign~, MAURICE BRUNELLE, pr~pos~ ~ la correction, jure que les pages qui precedent sont. et contiennent la transcription exacte et fiddle de l'enregistrement en langue frangaise. ET J'AI SIGN~ : MAURICE BRUNELLE AUDIOTRANSCRIPT, Divi,ion de Pi .... Wl .... & A,,oc,e,

1215 CANADA PROVINCE DE QUI~BEC DISTRICT DE MONTREAL COUR SUPI~RIEURE SOUS LA PRI~SIDENCE DE L'HONORABLE JUGE JEAN-JUDE CHABOT, J.C.S. No: 500-05-009755-883 KIR-MACDONALD INC. Requdrante LE PROCUREUR G~N~RAL DU CANADA Intimd No" 500-05-009760-883 IMPERIAL TOBACCO LIMITI~E Requ6rante LE PROCUREUR G~NI~RAL DU CANADA Intim6 2 octobre 1989 - Vol. 6 COMPARUTIONS " Pour la requdrante R JR-MACDONALD INC. Pour la requ6rante IMPERIAL TOBACCO LIMIT~E M¢ COLIN K. IRVING, Mt GEORGES R. THIBAUDEAU, EARL A. CHERNIAK. Q,C., M" MICHEL A. PINSONNAULT, Avocats SIMON V. POTTER. PIERRE BIENVENU. LYNDON A.J. BARNES. ESQ.. GREGORY BORDAN Avocats MACKENZIE GERVAIS Procureurs OGILVY, RENAULT Procureurs Pour l'intim6 LE PROCUREUR G~N~RAL DU CANADA M" ROGER E. BAKER. Q.C.. M' CLAUDE JOYAL, PAUL EVRAIRE, ESQ., Avocats COTI~ & OUELLET Procureurs AUDIOTRANSCRIPT, - Division de Vilaire & Associ~s - Sl~nographes Officiels - Courl reporters 4 est, Notre-Dame, Bureau 201, Montrl~al H2Y 1B8 -- T~I.: 871-1219

1216 682 INDEX PROOF OF PETITIONERS ROY DONALD BROWN Examination (Contd) (Me Potter) Cross-examination 687 780 AUDIOTRANSCRIPT, Divi,ion de Pierre Vilaire &

1217 683 ITL-9 ITL-10 ITL-II ITL-12 ITL-13 ITL-14 ITL-15 ITL-16 ITL-17 ITL-18 ITL-19 ITL-20 ITL-21 ITL-22 AG-19 AG-20 AG-21 AG-22 LIST OF EXHIBITS Ad "New Matinee Special Mild" (Indoor advertising) 708 Launch in-store advertising "Matinee Special Mild" 715 Ad with dark stripes for Matinee 717 Ad with pink stripes for Matinee 717 Document entitled: "Fiscal '80 Media Plans" 729 October 2nd issue of People Weekly Magazine 766 October 1989 issue of Life 769 "US" magazine, October 16, 1989 issue 771 "Home" magazine, October 1989 issue 773 "Newsweek" magazine 774 "Ms" magazine, October 1989 issue 775 "Sports Illustrated", September 25, 1989 issue 776 "Playboy" magazine, November 1989 issue 779 Budget de la marque de commerce du Maurier 780 (en liasse) 1 paquet avec 2 cigarettes "Premier" (i bris~e en deux, 1 compl~te) 795 "Canada's Wonderland" magazine, July 1985 issue 795 Project Viking Volume I - "a Behavioral Model of Smoking," February/March 1986 799 Paquet de cigarettes "M~daillon" 839 AUDIOTRANSCRIPT, Division de P; .... Viloi~'e & A,so¢i@s Lt4e

1218 684 LIST OF OBJECTIONS Objection ................ 845 AUDIOTRANSCRIPT. o;,,i,;o,~ ,~ P;,f,, Viloire & A,n,o~i~ Ll~e

1219 685 LIST OF UNDERTAKINGS Provide earnings for Imperial Tobacco for the year 1987 ............. Provide any correspondence in existence in connection with undertakings made by the people at Wonderland ........... Provide all scientific studies in the possession of Imperial Tobacco, either commissioned by Imperial Tobacco or not, either directly commissioned by Imperial Tobacco or commissioned by the Canada Tobacco Manufacturers Council which speak to the issue of consumption of tobacco and smoke connected with health ...... 783 795 853 AUDIOTRANSCRIPT, oi,,i,~oo a, P; .... Viio~re & A .... i,~, Ll4~e