Tobacco Products Control Act Trial
Document 009C
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A style of living. Is it intended by lifestyle
advertising to show cigarette smoking as a desirable
thing to do?
Well, I certainly couldn't say that it's intended to
show it as undesirable. I don't know that that's a
specific overall objective, but I think advertising
would want to make smoking shown in a positive way.
What is the effect on the consumer? If you'd be good
enough to tell the Court about this kind of advertising
showing smoking in a positive light?
I don't know the answer to that. I don't think we've
ever asked that. They try to describe the kind of
advertising research we do relates to specific
objectives for the advertisement. Any -- I think any --
I don't think -- I can't recall any specific objective
of making smoking look positive. I think there might be
tangential references, but I don't think it's ever been
measured, so I don't know.
But I thought you said you measured everything. I mean
you get it, as I understood it, Mr. Brown, sort of to
use the colloquial expression, coming and going.
I mean
you have the ads sketched up, first you have the
strategy about a brand, right?
Correct.
Right. Then you talk to your people, your own people
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about what a brand is supposed to look like, right?
Right.
Then you bring in your advertising guys and you tell
them what you think you want the brand to look like,
correct?
Correct.
Then somebody goes out and draws a little -- a couple of
pictures, I think you said, possibly, or brings you
photographs?
Correct.
Right. Then you have these qualitative focus group-type
things where you bring people in and you talk to them
about it and does it mean to them what it's supposed to
mean to them, right?
Correct.
And if you've shown them a lot of little pictures or
maquettes and stuff, you pick the ones for the campaign
that seem to get the people constant or their views
consistent with what you want that brand to represent,
right?
In broad terms, that's correct.
Right. Then -- then you get a little more professional
about it, I guess, and you get glossy pictures and you
put it in magazines and in billboards around the country
and in d~panneurs and stuff like that, in fact. Then
AUDIOTRANSCRIPT, Divlslon d, Pierre

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"A-
you start a media campaign in different kinds of media,
right?
Correct.
Right. Then once you've started that, you bring people
in to find out how you're doing, right?
We could, but -- yes. It's not -- that's less done by
that time. You judge your success in other ways, but it
-- yes.
You mean by your sales?
By your sales.
Amongst other things.
Yes.
Yes.
But you also bring people in to find out if the right
people's perceptions are right, correct? Don't you do
that, Mr. Brown?
Could you say it again, please?
You bring people in after a campaign has started to run
to make sure that their perceptions about the brand and
the advertising of the brand are the way you want them
to be perceived?
I think I just answered that. That would be done only
if we perceived that there was a problem, I think. Once
the ad has been advertised and I think I explained the
other day, and it's -- or I should say researched and
developed and then advertised, unless somebody felt
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there was a problem with it, probably not, no. Because
we would be convinced from pre-advertising research that
that represented what we wanted it to.
Therefore, if it was a what we have called or what
you've called lifestyle ad, and if the advertisement was
of lifestyle in its nature, you would have known in
advance that it was going to be perceived pretty much
the way you wanted it to be perceived, otherwise you
would not have run that ad; is that not correct?
That's pretty well correct, yes.
Okay. Therefore, is it correct to say or fair to say,
or answer to the question: what is the effect on the
consumer that lifestyle shows cigarettes as a desirable
thing to do, then if the ad has run, then the answer
would be that the effect on the consumer is that they
believe it or accept it the way we want them to accept
it. Would you agree with that, Mr. Brown?
I think I would agree with that, although, as I said, I
can't recall us having measured that specific objective,
but I would think so, that smokers -- certainly smokers
who chose that brand, one would assume they have
accepted that.
Would you say in a general way that smokers who chose
the brand have chosen the brand because of the
advertising that you have put on that brand?
AUDIOTRANSCRIPT, Division de Pierre Viloire & As,oci~s L,4e

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I would think that's true in part. There's a lot of
reasons for choosing a brand, obviously.
Right. Would you agree with me that there's a
reasonably close correlation between lifestyle
advertising and brand positioning?
There is in terms of brand positioning on certain
dimensions.
Okay. Now...
For example, the one that we referred to: for men/for
women, would be one that correlates with advertising
among other things, I would think.
For men/for women. How about for less harmful, milder
cigarettes to be less harmful? How's that for a
position?
I'm not quite sure I know how to answer that, except
that one of the ways that consumers, I believe, consider
the tar level of cigarettes is that the lower the tar,
the less harmful it is. I don't know if that answers
your question, but they would, I'm certain, respond in
that manner at large.
In fact, My Lord...
Oh, I'm sorry.
Perhaps I should clarify that more. I think that was
true up until a few years ago. I think that consumers
today are more accepting that all cigarettes are
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harmful. So perhaps I was inaccurate in saying what I
did relative to now.
Now, there's a correlation between targeting people and
positioning? Somehow you target people with certain
kinds of concerns or attributes and they're supposed to
attach some importance to the brand and in connection
with the advertisement so the people with the attributes
see certain attributes in the brand and the brand gets
positioned, right?
I think in a general flow, I would accept that.
Okay. So, but why does your company target health
conscious people, Mr. Brown?
My Lord, I'll answer that. I believe I've answered it,
but I will try again. There was a reference either
earlier today or yesterday to the "position of safety."
It is established among smokers, and has been for some
time, in fact by medical authorities and in fact by the
Health Department of Canada, that a lower tar cigarette
is better for your health. People who believe that and
are searching for lower tar cigarettes are referred to
in -- often as those people looking for the safest
position. And in fact in their minds a brand that was
the lowest tar would be the safest brand. Or they're
often referred to as health conscious people; in fact
they are.
AUDIOTRANSCRIPT, Di~i,~o~ d~ Pierre

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Referred to by whom?
Referred to in our documents, in -- you raised the word
"targeting."
I see.
It's quite common.
I see. So when we see...
But the point is...
THE COURT:
Let him finish.
Me BAKER:
All right.
A- ...that there was -- there was a need created in the
marketplace for lower tar cigarettes, and we believe
that was the reason, because they told us that, and we
gave them lower tar cigarettes. We did not, in my mind,
in any way, tell them they were safer or better for
their health. We told them they are lower tar
cigarettes because they said that's what they wanted.
Q- But -- so when we see in your corporation's documents
that your counsel have provided us with, you're
targeting health conscious people, we should ignore
health conscious and we should do what other people do
and that is sort of pretend that it really means mild?
A- I'm not suggesting you should ignore health conscious or
any of those references. I'm trying to explain what
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they mean.
Oh, I see. So...
They're trying to describe a group of people that have a
common feeling or understanding or something.
So is it your testimony then, Mr. Brown, that you don't
target health conscious people, what you really do is
target people who want a milder cigarette and they just
happen to be worried about their health?
I think that's semantic. We target to people who want
milder cigarettes because, as they have said, they think
they are better for their health. And that, by
definition, is health conscious people.
Well, I'll put it to you that you're changing your
answer somewhat from that of the sixth (6th) of June
nineteen eighty-eight (1988), page one sixty-eight
(168). I'm going to read a question and answer to you,
Mr. Brown.
"Q- Do you target specifically health
conscious people, health conscious in respect
of the cigarette smoking controversy?
A- That could be a definition and a target.
That could be a classification of people,
yes."
Now my question to you is...
It's the same thing.
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The Court will determine, Mr. Brown, whether it's the
same thing.
Sorry.
Please, don't you.
THE COURT:
Show me that passage.
Me POTTER:
Might I ask the page number, Mr. Baker?
Me BAKER:
Cent soixante-huit (168), je crois.
Q- This document, ITL-2, "Image Dimensions", you might --
maybe Mr. Potter would give you his copy, so that you
don't have to turn your back to the Judge. Now, these
things are called, if I remember your testimony,
discriminators, right?
A- Correct.
Q- Right. Let's see if I understand. When did you start,
your company first start using these discriminators?
These specific discriminators?
A- I don't know the answer to that because they do change
and I don't know when that exact list, as it is seen,
would have been created. In fact, since that's
eighty-seven ('87), there could be a couple that changed
now. I don't know that.
Q- Did -- it first started in eighty-seven ('87)? Didn't
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you do a youth study, or an image study in nineteen
eighty-seven (1987)?
No, we've been doing image measurement for longer than
that in the C.M.A. and then, as I think I mentioned
earlier, it switched from the C.MoA. to a separate
annual study.
Hm, hm. And did C.M.A. have a category called "Happy to
smoke/not happy to smoke"?
I think it would have, or something similar.
Hm, hm. I see. How long has your company known,
through its research, that consumers perceive milder to
be less harmful to their health, would you say? Five
(5) years, ten (i0) years, fifteen (15) years?
Quite a long time. I think -- I don't know when the
measurement started but I would say, as a generality, I
think, in my own view, that people have always felt that
a stronger cigarette was harder on you than a milder
cigarette, even in terms of comfort to your throat.
Harder on you, could that mean more harmful to your
health as well, Mister? Is that what you intended your
answer to mean?
It could be, yes.
I see.
Could mean that.
Could you tell the Court what Project Stereo was? Is
AUDIOTRANSCRIPT, Division 4, Pierre Vi;aire & Associ4s Lt4e
