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2064 1532 INDEX PROOF OF PETITIONERS LEONARD REID Cross-Examination (Contd) 1535

2065 2. 3. 4. 5. 1533 LIST OF OBJECTIONS Objection .................. 1545 Objection .................. 1548 Objection .................. 1553 Objection .................. 1554 Objection .................. 1557

2066 1534 i0 15 In the year of Our Lord nineteen hundred and eighty-nine (1989), on this twelfth (12th) day of the month of October, PERSONALLY CAME AND APPEARED: Me COLIN K. IRVING: Pour la requ~rante, RJR-Macdonald, Colin Irving et Georges Thibaudeau. Me SIMON V. POTTER: Pour la requ~rante, Imperial, Simon Potter, Lyndon Barnes et Pierre Bienvenu. Me ROGER E. BAKER, Q.C.: Pour l'intim~ dans !es deux (2) causes, Roger Baker, Serge Joyal et Lise Tremblay.

2067 i0 15 20 25 1535 In the year of Our Lord nineteen hundred and eighty-nine (1989), on this twelfth (12th) day of the month of October, PERSONALLY CAME AND APPEARED: LEONARD REID, WHO, having been duly sworn on the Holy Bible, doth depose and say as follows: CROSS-EX~INATION BY Me ROGER E. BAKER, Q.C., On behalf of Respondent: Q- Dr. Reid, you talked yesterday about selective attention, retention and distortion, and in connection with selective attention, you talked about a person's predisposition, psychological state. I'm referring you to page thirteen ninety-two (1392) of the transcript. I'll read it to you very quickly. THE COURT: Page... I'm sorry. Me BAKER: Treize quatre-vingt-douze (1392), Votre Seigneurie. You see at the bottom, at about line twenty (20)... Yes. ... "selective attention"? Okay.

2068 15 2O 25 Om 1536 LEONARD REID, Pet, Cr-ex So -- and then at page -- so a person's attention then is determined somewhat, attention to the advertisement, is determined somewhat by his predisposition and his psychological state, correct? Predisposition would be -- the psychological state would be part of a person's predispositions, yes. Right. So it doesn't necessarily have to be predisposition to the product? It could be a predisposition to the images that the person has of himself and of the product. The images as opposed to the product itself, correct? No, it could be a predisposition to exposure to advertising as well. Well, I suppose it could be a predisposition to a lot of things, but we're talking about a person's -- you used the expression "psychological state", so we're talking about the person's psychological state, correct? Correct. You see, when you turn the page, you talk about interest, the ad attracting their attention, and if you look at about line ten (I0), you talk about it being a product of interest: "They may be involved in or find important, something they find that's consistent with they way they see themselves."

2069 1537 LEONARD REID, Pet, Cr-ex i0 15 2O 25 Om You see, so that's person oriented as opposed to product oriented, is that a fair statement? Well, I think a person's reaction to any form of mass communication, including advertising, is a function of the situation, the person and the stimulus they find themselves encountered with, but yes. I mean, not to try to be wholly amusing, I mean, people don't think of themselves as refrigerators, people think of themselves in terms of their own psychological state -- unless they're crazy, of course. People have their own thoughts about themselves, their own self images and their own attributes, correct? Correct. And wouldn't that have been what you're referring to at page thirteen ninety-three (1393), about line thirteen (13), when you say: "something they find that's consistent with the way they see themselves."? Correct? I would say that selective attention is determined in part by the way people see themselves. Okay. So we were talking, if you recall, yesterday, about this notional or mythical sixteen (16) year old in a new market who, you know, whose parents didn't smoke and whose siblings didn't smoke and I asked you if that person could be attracted by the ad and become a user,

2070 1538 LEONARD REID, Pet, Cr-ex i0 15 2O 25 and you said: "Yes, it's theoretically possible in a new market", correct? I said: "Yes, it's theoretically possible." Right. Now, and it's more likely rather than less likely if the advertisement that the sixteen (16) year old is looking at has the same attributes as that sixteen (16) year old child has. You know, the -- consistent with the way that sixteen (16) year old sees himself, for example, in his own psychological state. I would assume that an ad designed in that manner would reflect the person's predispositions to respond. Right. So, just so we could focus this now, I had a little chart drawn and it's called."Cigarette market rising". Now, you're using a frame of reference called "New market". So just ignore the word "rising" in that chart. And I've also had blocked in, you see, nineteen seventy (1970) to nineteen seventy-five (1975). Now, you may find that difficult to accept as a new cigarette market, so just leave the date blank, all right? So... Okay. ... read across the top "New cigarette market", all right? All right. So we've got Peter on the right side, who's a non smoker, who's seen this ad, and it's got the attributes AUDIOTRANSCRIPT, 0;~,~o. ~. ~i.rr. Viloir~ & A~o¢,~s L~..

2071 1539 LEONARD REID, Pet, Cr-ex 15 20 25 that he's got and he buys the brand and tries the cigarette. It's possible, right? It's possible. Okay. It's possible and I did say yesterday too that Peter and John do not live in a world where they're only exposed to advertising. There are other factors that work as well as advertising because, as I said in page eight (8) of my testimony, that advertising's potential effectiveness is restricted or limited by the conditions of the marketplace. Hm, hm. Page eight (8)? Page eight (8). Right. You've got a good memory, sir. Now, that was a new market we were talking about. Let's talk about what you have called a mature market, nineteen eighty-eight (1988), and we don't have to make any changes on this one, sir. We see on this chart, we see the same sixteen (16) year old John on the left and the same sixteen (16) year old Peter on the right and assume they've come out of a time warp as it were, and it's the same set of factors, you see. Sixteen (16) year old Peter doesn't have parents who smoke and doesn't have siblings who smoke, but he has attributes, he wants to be cool and mature, and he sees

2072 1540 LEONarD REID, Pet, Cr-ex i0 15 2O 25 the ad. In a mature market, is it more likely or less likely that that sixteen (16) year old Peter is going to be attracted to the ad... My an... ... that appeals to his attributes, and is it more likely as a consequence of that that he might purchase the brand? As a part of your question, may I ask you to tell me what you mean by "time warp". Well, we were talking about Peter and John at an earlier period, so we're just taking another set of Johns and Peters, you see, and putting them in nineteen eighty-eight (1988), just to use the same names... Okay. ... so as not to confuse you. Well, first of all I would add, as I said yesterday in my discussion of a mature market, mature market, one of the tests of a mature market, as I define it, is based on the amount of awareness that a person has about the product category. And in nineteen eighty-eight (1988), a sixteen (!6) year old, whether it be Peter or John, is very unlikely not to have some knowledge of the product category cigarettes. The question is: is the sixteen (16) year old Peter, in nineteen eighty-eight (1988), as a consequence of seeing AUDIOTRANSCRIPT, 0i~,io. d, i:ierr, V[Joir, & Asso¢[~,

2073 1541 LEONARD REID, Pet, Cr-ex i0 15 2O 25 an ad which appeals to his own personal attributes, how he sees himself, a non user -- you remember, Peter is a non smoker -- more likely rather than less likely to be attracted to the advertisement, and as a consequence of that attraction, to purchase the brand being advertised? Well, there are two (2) different questions there. The first question would be whether Peter would be attracted to the ads. Yes, there is a possibility that Peter may be attracted to the ads. Whether those ads have some effect on Peter's purchasing of a brand of cigarettes, a precise brand, is extremely problematic in my view. Is it more problematic in nineteen eighty-eight (1988), when the market is mature, than it was when the market was new? Well, a new market -- your hypothetical example of nineteen seventy (1970) and nineteen seventy-five (1975)... No, I told you you could forget those dates. Okay. Based on the way I would think of a mature market, it's very unlikely, given the existence of cigarettes and people's socialization as consumers and experience with others, that they would be unknowledgeable of the product category cigarettes way before they're sixteen (16). Hm, hm. But, you see, you're looking at two (2) charts AUDIOTRANSCRIPT, o~,i,io~ ,~, ~i,,,, Viloi,,