Arnotts Limited v Trade Practices Commission

Case

[1990] FCA 847

29 Nov 1990

No judgment structure available for this case.

C A T C H W O R D S

TRADE. PRACTICES - Merger provisions - Acquisition by one biscuit manufacturer of business of a competitor - Whether the acquirer would be, or be likely to be, in a position to dominate a particular market; or, if the acquirer was already in that position, whether the acquisition would, or would be likely to, substantially strengthen its market power - Definition of the product market - Whether wider than biscuits

- Whether there are separate markets for different types of

biscuits - Substitutability - Whether Arnotts dominates Australian biscuit market - Criteria for determination of dominance - Whether acquisition would substantially strengthen Arnotts' position in the market.

EVIDENCE - Expert evidence - Nature of admissible evidence - Necessity to call expert evidence - Evidence of perceptions of facts - Reliance to be placed on statements in documents by

market research material.

unidentified authors - Admissibility and significance of of unnecessary evidence - Application to call fresh evidence on appeal.

Trade Practices Act 1974, ss.4, 4E, 50

Federal Court of Australia Act 1976, ss.27, 50

Evidence Act 1905, Part IIIA

Judiciarv Act 1903, s.79

Federal Court Rules 0.33,52

Arnotts Limited/Arnotts Biscuits Limited/~leds~ac

Limited/~he

D i c k e n s

C o r p o r a t i o n

P t v L i m i t e d v

T r a d e

P r a c t i c e s

C o m m i s s i o n

1

I

NO.

6 7 7 / 6 7 8 / 6 7 9 / 6 8 0

of

1 9 9 0

Arnotts

L i m i t e d / A r n o t t s

B i s c u i t s

L i m i t e d / F l e d s p a c

L i m i t e d / T h e

D i c k e n s

C o r p o r a t i o n

P t v L i m i t e d

v

T r a d e

P r a c t i c e s

C o m m i s s i o n

LOCKHART, WILCOX AND GUMMOW JJ

SYDNEY

29 NOVEMBER

1 9 9 0

IN THE FEDERAL COURT OF AUSTRALIA

) 1

NEW SOUTH WALES DISTRICT REGISTRY

) No. ~77/G78/~79/

)

G80 of 1990

)

GENERAL DIVISION

1

ON APPEAL FROM A JUDGE OF THE

FEDERAL COURT OF AUSTRALIA

BETWEEN:

ARNOTTS LIMITED

First Appellant

ARNOTTS BISCUITS LIMITED

Second Appellant

FLEDSPAC LIMITED

Third Appellant

THE DICKENS CORPORATION

PTY. LIMITED

Fourth Appellant

AND:

TRADE PRACTICES COMMISSION

Respondent

COURT :

Lockhart, Wilcox and Gummow JJ.

DATE :

29 November 1990

PLACE :

Sydney

MINUTES OF ORDER

THE COURT ORDERS THAT:

The appeals be dismissed.

Note :

Settlement and entry of orders is dealt with in

Order 36 of the Federal Court Rules.

IN THE FEDERAL COURT OF AUSTRALIA

)

1

NEW SOUTH WALES DISTRICT REGISTRY )

No. G77/G78/G79/G80

)

of 1990

GENERAL DIVISION

1

ON APPEAL FROM A SINGLE JUDGE OF

THE FEDERAL COURT OF AUSTRALIA

BETWEEN :

ARNOTTS LIMITED

First Appellant

ARNOTTS BISCUITS LIMITED

Second Appellant

FLEDSPAC LIMITED

Third Appellant

THE DICKENS CORPORATION PTY.

LIMITED

Fourth Appellant

AND :

TRADE PRACTICES COMMISSION

Respondent

COURT

:

Lockhart, Wilcox and Gummow JJ.

DATE :

21 December 1990

PLACE :

Sydney

CORRIGENDUM

Amendment to the reasons for judgment of the Court delivered

29 November 1990:

Paae 109, woint 5: Delete "yet it was a major reason why the trial took over seven months." and substitute a full stop for a semi-colon after "absurdity".

-- /J

Associate to

Mr Justice Lockhart

IN THE FEDERAL COURT OF AUSTRALIA

)

1

NEW SOUTH WALES DISTRICT REGISTR

Y

) No. G77/G78/G79/

)

G80 of 1990

l

I

)

GENERAL DIVISION

1

ON APPEAL FROM A JUDGE OF THE

FEDERAL COURT OF AUSTRALIA

BETWEEN:

ARNOTTS LIMITED

First Appellant

ARNOTTS BISCUITS LIMITED

Second Appellant

FLEDSPAC LIMITED

Third Appellant

THE DICKENS CORPORATION

PTY. LIMITED

Fourth Appellant

AND :

TRADE PRACTICES COMMISSION

Respondent

COURT

:

Lockhart, Wilcox and Gummow JJ

DATE :

29 November 1990

PLACE :

Sydney

REASONS FOR JUDGMENT

THE COURT: This case concerns 9.50 of the Trade Practices

Act 1974. On 24 November 1988 Arnotts Biscuits Limited,

("Arnotts"), a wholly owned subsidiary of Arnotts Limited, and

Fledspac Limited ("Fledspac")

entered into an agreement

2.

whereby Arnotts was granted by Fledspac an option to purchase

Fledspac's shares in The Dickens Corporation Pty Limited

("Dickens"),

a wholly owned subsidiary of Fledspac, and

Fledspac was granted by Arnotts an option to require Arnotts to purchase those shares. The agreement provided for the exercise of the options between 1 January 1990 and 30 June

1993. Dickens owns all the shares in a company, Cereal Foods

Pty Limited, formerly known as Nabisco Brands Pty Limited, which manufactures biscuits and cereal products. For convenience we shall refer to that company as "Nabisco", the name under which it is best known.

The Trade Practices Commission ("the Commission")

brought a proceeding in the original jurisdiction of this

Court to restrain the acquisition of the shares on the ground

that it would constitute a contravention of s.50 of the Act.

Section 50 prohibits certain mergers and other acquisitions.

The learned trial Judge, Beaumont J, found that the

grant of the option to Arnotts to acquire the shares was a deemed acquisition of those shares: see S. 4(4)(a) of the Act, which provides that a reference in the Act to the

acquisition of shares shall be construed as a reference to an contravened s.SO(l)(b) of the Act and a further declaration that Fledspac and Dickens were involved in the contravention: see s.75B of the Act.

acquisition of any legal or equitable interest in shares. His

3 .

When he delivered judgment on the principal issues

in the case his Honour delivered a second judgment concerning

the admissibility of the evidence of an expert economist

called by the appellants, Dr. Phillip Williams. His Honour

ruled that the evidence of Dr. Williams was inadmissible.

These appeals are brought from the two judgments of

Beaumont J. His Honour's findings that the grant of the option to Arnotts to purchase the shares in Dickens created an equitable interest in the shares, and therefore constituted an "aqquisition" of shares for the purposes of s.50, were not challenged on appeal.

Fledspac and Dickens, the third and fourth

appellants, played no active part in the appeals. They

adopted the submissions of counsel for the first and second

appellants, Arnotts Limited and Arnotts.

For convenience we

shall refer to those two appellants as "the appellants". Counsel for the appellants submitted that the trial Judge erred in his three principal findings on substantive issues:

that the relevant market is the Australian biscuit market;

that the concept of dominance which is embodied in s.50

extends to Arnotts' position, and that the effect of the

acquisition would be substantially to strengthen its market

power, Counsel also criticised numerous evidentiary rulings

made by his Honour. We will deal with each of the three

principal issues and the more important evidentiary questions.

Some of the more minor evidentiary matters were disposed of

during argument.

The course of the trial

Before turning to these issues, it is appropriate to would be likely to, substantially strengthen its market power; it being common ground that the Nabisco biscuit business competes with that of Arnotts. say something about the course of the trial, aspects of which

cause us concern. As we have indicated, the principal issue

in the case is whether the acquisition by Arnotts of the

biscuit business conducted by Nabisco would contravene s.50 of

the Trade Practices Act. That would be so if, as a result of

the acquisition, Arnotts would be, or would be likely to be,

in a position to dominate a particular market for goods or, if

The investigation of these practical questions of

fact involved a trial occupying 110 hearing days, spread over

nine months. The hearing generated some 6,500 pages of

transcript and 292 exhibits. Most of the exhibits were

lengthy documents. Many occupied one or more large ring-bound

folders. Stacked side-by-side in folders, the exhibits extend

for some five metres.

In total, they contain tens of

thousands of pages. The trial Judge found it necessary to

refer in his reasons for judgment to only a handful of those

documents, although no doubt he read them all. But we were

not asked to do this. Although, before us, the appellants

attacked his Honour's findings on almost every significant

factual issue and many of his evidentiary rulings, and

although both parties supplied us with extensive written

submissions supplemented by seven days of addresses, counsel

found it necessary to refer us to only a tiny proportion of

the oral and documentary evidence; perhaps no more than two

per cent of it. We acknowledge that it is usually unnecessary

on appeal for counsel to refer to the whole of the evidence

led, and properly led, at the trial. We also acknowledge that

material which itself has no evidentiary value is sometimes

properly tendered in order to provide a context for other

material. However, making these allowances, the comparison

just made raises immediate doubts about the utility of much of

the evidence tendered at the trial. Those doubts are

abundantly confirmed by examination of the material itself.

A large proportion of the documents tendered in

evidence comes from the records of commercial organisations:

biscuit manufacturers and retailers. In most cases, it would

seem, the person producing the documents to the Court, or

tendering them in evidence, claimed that they contained

commercially confidential information. So the trial Judge

made orders under s.50 of the Federal Court of Australia Act

1976 limiting access to those documents.

Access was usually

confined to the lawyers engaged in the case and any

independent experts advising a party. One result of these

orders was that counsel and witnesses were inhibited in their

references to the contents of documents unless the Court was

b .

closed to the public, as it frequently was. A further result

became apparent when judgment was delivered. The

"confidential" documents included a good deal of information

about the size and structure of the biscuit industry,

including the market shares of the major manufacturers. This

information is basic to a coherent discussion of the case. It

was material which the trial Judge rightly thought necessary

to set out in his reasons. Furthermore, as it happened, his

Honour relied heavily upon these documents for his conclusions

that the relevant market was properly to be described as "the

Australian biscuit marketM and that Arnotts already enjoyed a .

dominant position in that market.

In an unexpurgated version

of his reasons, his Honour set out information about the

industry which he had gleaned from the "confidential"

documents. He also quoted the relevant documentary passages

upon which he relied for his findings on the issues of market

and dominance, and explained how they supported his

conclusions. But the unexpurgated version was made available

only to a limited number of people, not even including

executives of Arnotts. In deference to the claims for

confidentiality, the trial Judge felt constrained to issue an

expurgated version of his reasons, for a general audience,

from which all citations from the "confidential" documents

were omitted. That version lacked both basic information and

intelligibility; it is reported, (1990) 93 ALR 657. It is not

until one reads the unexpurgated version that one can gain any

real understanding of his Honour's findings of fact or

processes of reasoning.

7.

We do not know what their reactions were, but it would be understandable if the executives of Arnotts felt aggrieved at being denied an intelligible explanation of their

loss of an important case upon which their company must have

spent millions of dollars. Furthermore, the general community

has an interest in knowing the reasons for the outcome of a

major case affecting many people outside Arnotts and into

which substantial public funds have been poured.

We recognise that there are documents which are truly confidential, whose dissemination to competitors or to

the general public might cause irredeemable commercial harm.

Obvious examples are documents containing information about

secret manufacturing processes or ingredients; perhaps future

1

marketing strategies, lists of suppliers, customers and the

like. Where such documents become involved in litigation, the

disadvantages of restricting access may have to be accepted in

order to avoid injustice to their owners or authors. But few

of the documents for which claims of confidentiality were made

in this case seem to have been truly confidential. Neither

before nor during the hearing of the appeal did we carry out

any comprehensive review of the confidentiality orders; we

were not asked to do so. But, from time to time, the matter

of confidentiality did arise. When we asked counsel why

particular documents had been thought to be confidential, the

claims of confidentiality melted away. In the end it was

conceded, not only by the parties to the appeal but also by

counsel for George Weston Foods Limited ("Weston")

- whose

9.

commercial litigation: that, when big issues are at stake,

there must inevitably be a long and complicated hearing. This

assumption must be discarded. No matter how much is at stake,

in dollar terms, there is no justification for irrelevant or

unuseful evidence. Moreover, it is in the interests of the

parties to analyse properly the cases which they wish to make

and to restrict themselves to helpful material; and not only

because of savings in costs. The devotion of excessive

attention to peripheral matters, rather than the main issues,

causes the parties to lose sight of the real issues and to

devote insufficient attention to them. The result may be to

leave the Court with insufficient or unsatisfactory material

upon principal factual issues. The essence of counsel's

function is the identification of, and concentration upon, the

critical issues in the case.

A remarkable feature of the present case is that,

when the smoke all clears away, most of the critical facts which we have identified. We will deal with each of these issues separately; but first it may be useful to give a brief account of Arnotts' business.

stand clear and uncontroversial. We are satisfied that

Arnotts' business

The founder of Arnotts was William Arnott, a

Scottish emigrant who established the business of a baker and

10.

pastrycook at West Maitland in 1850. In 1894, a factory was

acquired in Sydney. In 1904 the business was acquired by a

company formed for the purpose, then named William Arnott

Limited. In 1949, the company acquired an established

Brisbane biscuit manufacturer, Morrows Pty Limited.

Subsequently, other established businesses were acquired: the

Guest and Brockhoff businesses in Melbourne and businesses in

I

Adelaide and Fremantle. All of these businesses had been founded in the 19th century as family concerns. In about 1976, Arnotts took over the business of Peek Frean (Australia)

Pty Ltd, the Australian subsidiary of a British biscuit

a

manufacturer.

There has also been a degree of vertical integration

and product diversification. In 1965, the Arnotts group

acquired a controlling interest in a Victorian potato chip

business.

In the next year a subsidiary was formed to

manufacture, in Sydney, potato chips for distribution in successful business. A 66% per cent interest was acquired in Cardboard Manufacturing Co. Pty Limited, a company supplying a steadily increasing proportion of the group's requirements for corrugated cartons. In 1971, a controlling interest was acquired in McCorquodale Holdings Pty Limited, a flour milling and stock feed company based at Parramatta in New South Wales. Two years later a controlling interest was obtained in Kingaroy Toasted Peanuts Pty Limited. A manufacturer of pet foods was acquired in 1982.

11,

By the time of the trial the Arnott commercial empire involved assets of approximately $800m and a share

l ,

capital of $7m. The parent company, Arnotts Limited, has a

large number of subsidiaries in Australia and abroad. The

operating revenue of the group for the year ended 30 June 1988

was $709m. The principal activities of the group are the

manufacture and distribution of biscuits, formula dietary

foods, snack products, cakes, pet foods, confectionery, bread,

jam, nuts, packaging,materials,

containers, flour milling and

engineering. Arnotts itself is a major Australian

manufacturer of food products; including biscuits, cakes and

W .

1

confectionery. Biscuits represent the major part of Arnotts'

business.

The biscuits manufactured and sold by Arnotts

include a number of well established brand names. The "Milk

Arrowroot" biscuits made their appearance in about 1880.

"S~O", "Assorted CreamsM, "Family Assorted", "Scotch Finger", "Gingernut" and "Shredded Wheatmeal" biscuits have all been

marketed since at least 1906.

"Monte Carlo" and "Spicy Fruit

Roll" were introduced in the 1920's.

The dry cracker

biscuits known as "Jatz" and "Salada" were introduced more than 25 years ago. The evidence indicates, on the part of consumers, strong recognition of Arnotts' brand, which is

displayed on distinctive packaging. Arnotts' biscuits are

perceived by consumers as the best quality biscuits, but as

more expensive than other brands.

12.

The "Premiere" brand is used by Arnotts for products

specially imported to fill "market gaps" or "niches" in the

"exclusive type market", where the potential volume of sales

appears not to warrant the capital expenditure on

manufacturing equipment that would be necessary for Australian

production. In addition, Arnotts supplies "Sunshine" brand biscuits at the lower-priced end of the market.

The Australian biscuit industrv

Beaumont J found that there was a "market",

within

the meaning of ss. 4E and 50 of the Act, being a national Coles Myer Limited (the "New Worldw supermarkets), Franklins Ltd, Woolworths Ltd, and the buyers comprised in Amalgamated Australian Wholesalers Ltd. The evidence included considerable detail about some of the participants in the market determined by his Honour. In other cases, the material was more sketchy. We will set out such of the evidence - none of which was controversial - as is necessary for the purpose of considering the appellantst challenge to the trial Judge's

market for the supply of biscuits to wholesalers and

retailers, and that there were two principal players therein,

in addition to Arnotts, namely Nabisco and Weston. About 90%

of biscuits supplied by the participants in this market are

supplied to the major retail supermarket chains or to large

grocery wholesalers. The four principal purchasers of

finding

.

13.

Over the three years ending 30 June 1988, Arnotts

supplied approximately 65% of the biscuits consumed in approximately 148, was divided between imported biscuits (excluding biscuits imported by Arnotts and marketed under the name "Premiere") and the product of other Australian manufacturers.

In 1988, the total Australian biscuit market had gross wholesale sales of about $600m. The total volume in 1985/86, 1986/87 and 1987/88 was 135,720,900 kgs, 135,545,900 ,

kgs and 137,946,000 kgs respectively. There are approximately Pty Limited, which in 1987 successfully launched a range of chocolate biscuits. But none of these other manufacturers has offered a product range comparable to that of Arnotts, Nabisco and Weston.

26 manufacturers and importers of biscuits, in addition to

In some of its "New World" supermarkets Coles Myer

sells biscuits baked on the premises. Further, in 1989, it

launched a range of biscuits, manufactured for it under

contract and marketed under its "in house" brand "Farmland".

The other supermarket chains also sell "generic" biscuits and

"in house" brands at lower prices than Arnotts' biscuits.

However, Arnotts uses its "Sunshine" brand to compete with the

"in house" and generic products sold by the supermarket

chains.

The generic and "in-housew products are manufactured

primarily by Paradise Food Industries Pty Limited ("Paradisew) gave this evidence about the difficulties confronting a new biscuit manufacturer:

and Players Biscuits Pty Limited ("Players"). Paradise

commenced operations in Brisbane in March 1986. The Joint

"Very great difficulties face anybody entrant to the market. Because the capital cost in establishing a biscuit manufacturing plant is high, it is necessary to have a reasonably high level of sales or potential sales to make the capital outlay attractive. Obtaining staff with biscuit production skills and machinery operation skills is also difficult. New product development costs are also significant. There is also a significant cost in maintaining inventory levels which are high in relation to the size of sales. In addition, a new entrant proposing to supply branded biscuit products is also faced with new product listing fees charged by the various wholesalers and retailers of biscuits."

wishing to manufacture biscuits in

Players commenced manufacturing biscuits in 1974 or

Before their expansion into Australia, the companies in the Papua New Guinea for over 30 years. The value of Australian sales grew from $175,279 in 1986 to $3.62m. in 1988; still a small percentage of the $600m. national market for that year.

1975. It commenced to supply the major supermarket chains

with generic or "home brand" biscuits in about 1984. It has a

15.

factory in Sydney which was opened in 1988. The factory has a

floor space of some 120,000 sq. feet. It was constructed and

outfitted at a cost of $12m. This sum includes the cost of

plant and equipment, said to incorporate "state of the art"

I

technology. For the year ended 30 June 1989, the total sales

of Players' biscuits amounted to $19.7m.

In the late 197Ots,

Arnotts, Nabisco and Weston had

supplied some 98% of the biscuits consumed in Australia, the balance being highly priced imports. Biscuits imported from New Zealand are now duty free. Duty on other imports is

presently at'a maximum of 2%. The result is a significant

expansion in the volume of imports.

Weston is ultimately foreign owned, being a

subsidiary of Associated British Foods plc, a large, broadly

based food producer. It is a major flour miller and supplies

the Australian food industry with flour, starches, gluten and

a wide range of bread, cake and pastry mixes.

It also

manufactures and supplies stock feed, small goods and dairy products. The evidence does not indicate the year in which Weston entered the biscuit market in Australia, but it was

before the advent of Nabisco.

The Australian operations of Nabisco commenced some

20 years ago. In addition to biscuits, Nabisco manufactures

breakfast cereals and processed nuts, This last branch of the

business dates from 1978. Nabisco has always been ultimately

16.

foreign owned. On 1 July 1988 the group was acquired by the

ICM group of companies, which uses the business name "Best

Foods". The group is, in particular, a supplier of cereal foods, principally under the trade mark "Uncle Tobys". In biscuits, the Nabisco strength is dry crackers, flavoured

snacks and chocolate biscuits; whilst Weston is strong in

assortments, cookies and chocolate biscuits. Arnotts covers

the entire range of products. Six to ten new lines are

introduced each year by each of the three major manufacturers.

.

Retail margins vary, usually between 15% and 20%.

The size of the margin tends to be related to the volume of products sold. There is a practice among retailers of taking lower margins on top selling lines, often below 10%. The result is to exert price pressure on products having low market shares. The manufacturers of those products need to keep margins slight so as to remain competitive with the leading brands.

Nabiscots biscuit products are manufactured at the

company's plant at Broadmeadows, Victoria. The company has a

warehouse in each capital of the other States, to which the

biscuits are transported from Broadmeadows.

Arnotts has

factories in all States except Tasmania. Weston is established

at Camperdown in New South Wales, Kedron in Queensland and

Abbotsford in Victoria.

The three major biscuit manufacturers operate their

own transport fleets to carry supplies directly from their this way. Other biscuit suppliers depend upon retailers to get their products to the stores. For example, Coles' "New World" distributes the products of other suppliers through its own distribution system. But it requires these suppliers to

plants or warehouses to the supermarkets. They do not use the

central warehousing facilities offered by the supermarket

chains. The reason is that biscuits have a relatively short

shelf life. Direct supply assists the sale of fresh stock.

allow a distribution discount, equivalent to the cost of

'

distributing the goods, which is deducted from the wholesale

price of the biscuits.

The operations of the grocery wholesalers vary

somewhat, but the Queensland Independent Wholesalers Group ("QIW") may serve as an example. QIW supplies most of the grocery retailers in Queensland and northern New South Wales

(some 1,400 stores) with the exception of the Coles Myer, distribution centre in Brisbane. Supplies of biscuits are kept at 13 "cash and carry" warehouses throughout Queensland, QIW biscuit sales being divided equally between the Brisbane facility on the one hand and the "cash and carry" warehouses on the other. The smaller retailers buy their supplies from the cash and carry warehouses. The larger independent retailers place orders on the three major manufacturers, which

deliver directly to these retailers.

But the manufacturer

invoices QIW which bills the retailer; then the retailer pays

QIW and QIW pays the manufacturer.

Arnotts, Weston and Nabisco and, to a lesser extent,

the smaller suppliers provide a merchandising service for

their products in the retail stores. Representatives visit

stores. They check the stocks of biscuits on the shelves

(particularly as to the expiration of "use by" dates) and

furnish promotional material for display.

In recent years, at

least, Arnotts has had a group of highly effective

representatives. They frequently visit the stores in their

areas and provide the company with detailed and astute "grass-

roots" market intelligence.

A set of statistics, known as the Biscuit Industry

Statistics ("BIS"), is maintained. These statistics relate only to the operations of Arnotts, Weston and Nabisco, The industry treats BIS as a reliable indicator of the performance

of the three leading members of the industry; but, of course,

they cast no light upon the performance of others.

The trial Judae's findinas

In his reasons for judgment Beaumont J stated his principal conclusions in seventeen numbered paragraphs:

"1. There is a national biscuit industry

of which the clear leader is Arnotts. It is, by far, the largest manufacturer, its products are of the highest quality and it

is the only manufacturer to produce the

whole range of biscuits available. 'contain' the competition. As Weston1s management recognised, Arnotts is able 'to influence market situations at will'.

Arnotts manufactures the best selling

product in each of the groups which

constitute the range of biscuits marketed

in Australia. Weston and Nabisco are also

large manufacturers of biscuits in terms

of volume, but the size of the operations

of Weston and Nabisco, relative to

Arnotts, is small. From time to time,

Weston, Nabisco, Cadbury, Players,

Paradise and generic biscuits (or 'house

brands' of some of the large retail

chains) have offered competition to

Arnotts in certain areas in the short

term. But no competitor has even sought

to compete with Arnotts over its whole

range and, even when competition is

offered in a particular product category,

2. Arnotts' major brand in all trading

areas is the 'Arnott' brand. Arnotts has

succeeded in marketing this brand so as

'to equate products with a certain

standard of quality in consumers' minds'.

Arnotts aims to give, and, it seems, has

given, 'meticulous' attention to the

'Arnott' brand so as to 'ensure

competitive advantage in performance,

function and value'.

3. Arnotts' 'Sunshine' brand is used on

products designed to 'contain', and it

appears do contain, 'low price, private

label and generic competition in defence

of the major brand in each trading area.'

4. The 'Premiere1 brand is used for

products specially imported to fill

'market gaps' ('niches') in the 'exclusive

type market' where potential volume does

not warrant capital expenditure for

manufacturing equipment.

5. Arnottsl 'product mix' policies,

which are concerned only with the 'biscuit market1, adopt the following product group definition for its biscuits, based on

production characteristics and historical

measurement: Dry crackers, flavoured

snacks, crispbread, plain assorted, plain

non-assorted, fancy assorted, fancy non-

assorted, cookies, shortbread, and

chocolate coated. The biscuit industry 'miscellaneous' group, neither of which appear to be significant for present purposes.

adopts a similar approach. In addition,

6. An important object of Arnotts' style

of packaging is to enable 'prompt

discovery and identification' of the

Arnotts

' brand.

7. Arnotts' pricing policy is to ensure

that any price increases to offset rising

costs are 'limited to ensure that products

always represent good value to the

consumer, make it difficult for

competitors to offer comparative value and

offer the retailer a better profit/volume

relationship than most grocery store

items.' Arnotts' aim to stabilise prices

and margins'. When 'pricing to contain

competition, whilst [Arnotts] do not aim

to be 'cheaper' than competitors,

[Arnotts'] pricing strategy is always to

ensure that we do not price our major

products to present a significant threat

to our share/volume/profit position

through non-competitive pricing.' The

size and historical position (over 120

years) of Arnotts in the industry puts it

in the position of 'price leaders', a

situation in which 'competitors generally

follow any deviation in price, especially

upward.' Arnotts' ability to maintain a

'price leader' policy is reinforced by its

'strong consumer franchise, consistent

advertising, volume production and

technological leadership.'

8. Arnotts' basic principle is that its

trading terms and conditions are the same

for every retailer and prices and

discounts are 'arranged to enable any

retailer of reasonable size to trade to

maximum margins.'

9. Because of its position as 'market

leader', Arnotts makes a 'substantial

investment' in marketing.

10. Arnottsf national biscuit marketing

objectives for 1987/1988 were:

(1) To maintain a profitable growth in

total kilogram sales.

(2) To 'maintain a dominant market

position'.

The aim was to achieve

and maintain 'a market share of not

less than 70% of the total Australian

biscuit market.'

(It is not clear

measured by volume or by sales value.

whether the 70% objective was to be by volume and rather more if measured by the value of sales.) A second aim was to achieve and maintain a 'market share of not less than 75% as measured in the B.I.S. figures for

Total Biscuits Sales.'

(This was

achieved.

)

(3) To establish and maintain 'profitable

leadership' in each product group.

The first objective was to have 'more

than a 60% market share in any single

group'. (This was substantially

achieved. Taking the B.I.S. national

figures for 1988, the only product

group of Arnotts with less than 60%

were crispbreads - extruded (57.83%)

and crispbreads - non-extruded

(53.63%)). The second objective was

to have the best selling product in

each group.

(This objective was

achieved)

.

(4) To introduce new products to (a) add

variety to Arnotts' product range

(this was achieved);

(b) 'overcome

competitive activity where

competitive new products are seen to

represent a long term threat in

present and new markets' (it appears

that this was achieved); (c) fill

gaps in Arnotts' range: created by

deletions (variety and brands),

'emerging competitive strengths' or

new market development (it appears

that this was achieved).

high proportion of its biscuits through

the major retail supermarket chains or

through the large grocery wholesales.

11. The biscuit industry markets a very 'biscuit barsr in which Arnotts' biscuits are first in the traffic flow and occupy about 50% of the bar. This confers a considerable marketing advantage upon Arnotts. It is very difficult, and very expensive, for a new entrant to the

biscuit industry to obtain access to Arnotts, but Arnotts has been able, generally speaking, to maintain its position of first in the traffic flow, and occupying 50% of the biscuit bar. The strength of Arnotts' position in this respect has provided a considerable barrier to any new entrant to the biscuit industry.

'facings', or shelf space, in biscuit bars

in supermarkets. There are suggestions in

the evidence that, on occasions, the

retail chains have indicated interest in

encouraging a new entrant (e.g. Players,

12. Biscuits are marketed separately from other processed foods such as snack foods, confectionery and bread. From time to

J. (with the general-agreement of Dawson J. ) pointed out in Queensland Wire [(1989) 167 CLR 177, at 1961, the 'outert limited of a market are likely to be 'blurred'.

time, the management of the biscuit and the discussion of the introduction of sales tax on chocolate biscuits in 1985 show, even in the case of chocolate biscuits, the biscuit industry recognises, and acts upon the recognition, that the biscuit industry should be distinguished from the confectionery industry. Hence the need to package and market a biscuit differently if it is to be sold as confectionery. The general position is that the biscuit industry is self- contained. Generally speaking, as the 'competitive activity' reports indicate, the members of the industry confine their attention, and their conduct, to the biscuit marketing efforts of other biscuit manufacturers. By and large, biscuit producers do not concern themselves with the activities of the manufacturers of other kinds of processed foods. I say 'by and larget because, as Deane

industry has noted the possibility of

threats from, or opportunities in, the

snack food industry, the confectionery

industry and the bread industry. But

these threats, or opportunities, are

unusual and, when they occur, they are

confined to a specific category of

biscuit, e.g. chocolate biscuits, and do

not involve biscuits generally. As the

in the cracker and savoury segment, with

approximately 90% in volume and

approximately 95% 'in dollar terms' of

biscuit sales in Australia. This explains

why the management of Arnotts, Weston and

13. The B.I.S. figures deal, for instance exclusive, reliance upon these statistics. It also explains why Arnotts' management devotes so much effort to the process of monitoring the trading activities of Weston and Nabisco.

14. Weston's management recognised that

Weston's performance was hindered by,

inter alia, the following: (1) Weston does

not compete in the cracker, flavoured

snacks segment ('23% of the total

market'). (2) Arnotts and their other

brands have a 'stranglehold on the

domestic market in relation to range,

price structure and

advertising/promotional activities.'

(3)

The advent of generics has weakened its

image as the 'value for money'

manufacturer. (4) The 1985 sales tax has

'narrowed' the 'differential' between a

packet of chocolate biscuits and a block

of chocolate. Biscuit sales have 'slowed'

in 'almost every segment but particularly

in the high priced chocolate range', (5)

Chain store 'dominance' of the trade is a

'cause for concern' to all food

manufacturers. Their 'dictatorial'

attitude in relation to promotional

funding and trading terms places 'great

strain' on the relationship between

manufacturer and retailer. Independent

retailers are losing their share of the

market as chain store sales increase in

volume.

cause for concern for Weston, it appears

that, on the whole, relations between

Arnotts and the chains are mutually

satisfactory. The history of the

relationship between Arnotts and each of

the chains, generally speaking, is

consistent with an attitude of co-

operation between them. Whatever power

the chains may exercise over the smaller

players, including Weston and Nabisco, the

evidence indicates a recognition by

15. Although the retail chains are a each other. There is no evidence that the

chains have a 'dictatorial1 attitude retailers, Coles New World, actually described Arnotts as a 'dominant market

towards Arnotts. This is consistent with

their recognition of Arnotts' position as

the clear leader of the biscuit industry.

leader

' .

16. Nabisco's management recognised, and

acted upon the recognition, that Arnotts

have a 'dominant' share of the 'total

biscuit market'.

17. Over the three years ended March

1986, 1987 and 1988, the 'Arnottl brand

share remained stable, irrespective of

what happened in the case of the

'Sunshine' brand, Weston, Nabisco, imports

and generics."

See (1990) 93 ALR at 695-697.

His Honour held that there is in Australia an area of "close competition" in the supply of biscuits, that there is a "market" for biscuits in the sense explained in the

authorities and that the market is a substantial one. He held

that the "product market" is biscuits and the "geographic

market" is Australia.

The trial Judge dealt with the question of dominance

and found that:

"An enterprise will be in a position to

dominate a market when there is a

probability that the other enterprise or

enterprises in the market will act in a

way calculated not to affect adversely the

dominant concern's short term interest.

Dominance, unlike control, is not

primarily concerned with the formal

relationship between entities but rather

with their conduct towards each other competition but enables the undertaking which profits by it, if not to determine, at least to have an appreciable influence on, the conditions under which the competition will develop and, in any case, to act largely in disregard of it so long as such conduct does not operate to its detriment."

within a particular market environment.

If the size or strength of a particular

entity is such that, in practice, other

entities are unable or unwilling actively

to compete with it in a particular market,

that entity is dominant in that market.

The dominant position relates to a

position of economic strength enjoyed by

an undertaking which enables it to prevent

effective competition being maintained in

the relevant market by affording it the

power to behave to an appreciable extent

independently of its competitors, its

customers and ultimately of the consumer.

See (1990) 93 ALR at 668.

His Honour found that Arnotts was in a position to

dominate the market, that it has held for many years a very

large market share and that it has had some, but not much,

competition in the supply of biscuits. He said that the

members of the biscuit industry and the members of the grocery

trade act upon the belief that Arnotts is in a position to

exercise, and does exercise from time to time, a commanding

influence in the market. The size and strength of Arnotts is

such that in practice other entities are unable or unwilling

to offer any significant competition to Arnotts in the biscuit

market in the medium or long term. Even in the short term,

there is an obvious reluctance to meet Arnotts "head-on" or

directly. Instead, other suppliers of biscuits seek to find

26.

"gaps" or "niches" in the market.

Beaumont J held that this

conduct is an indication that Arnotts holds a commanding

influence in the market.

His Honour dealt with the meaning of the word

"substantially" in s.SO(l)(b)(ii).

He said that, in his

opinion, it suggests a degree of strengthening of power that is "real or of substance and not insubstantial or nominal", relying upon Tillmann's Butcheries Ptv L t d v Australasian Meat

Industrv Em~lovees'

Union (1979) 42 FLR 331 per Bowen CJ at

338-9 and Deane J at 348. Reference was also made by his

*

Honour to B. v Hudson (1985) 63 ALR 257 at 270.

Beaumont J concluded that Arnotts' acquisition of

Nabisco would, or would be likely to, substantially strengthen cited two considerations in support of that conclusion.

First, his Honour said that Nabisco has about 8% of

share. In two important sections of the market - dry crackers

and flavoured snacks - Nabisco is Arnotts' only competitor.

the total Australian biscuit market and about 9% of the BIS "sheer volume" and the "growth rates being achieved disproportionately to the total biscuit market". His Honour accepted evidence that, if Arnotts had no significant competitor in these segments of the market, its power to bargain with retailers in these areas, at least, would be

27.

considerably enhanced. Secondly, Beaumont J thought that this size.

Having concluded that Arnotts is in a position to

dominate the market in Australia for biscuits and that the

acquisition of the shares in Nabi-sco by Arnotts would

substantially strengthen the power of Arnotts to dominate that

market, his Honour said that it followed that the deemed

"acquisition" of shares under the option agreement contravened

s.SO(l)(b).

The trial Judge found that Fledspac and Dickens were

also "involved" in the contravention within the meaning of S.

7SB(1) of the Act. He said it further followed that any

actual, as distinct from any deemed or notional, acquisition

of the shares by virtue of the exercise of any option granted

by the option agreement would also contravene s.SO(l)(b).

Counsel for the appellants criticised the

sufficiency of the factual findings made by Beaumont J, one

submission being that - for this amongst other reasons - there

ought to be a new trial. In response to this submission we

feel bound to say that, whilst it would be unreasonable to

expect his Honour to have made findings relating to all the

matters of fact put before him, his findings were rather

sparse. We would have benefitted from a much fuller account

of the effect of the evidence in relation to the critical

issues. In the situation we encountered, we have had to spend

more time winnowing the primary facts from the mass of

I

evidence than we would have expected, Fortunately, we have

had considerable assistance from counsel in this task, leading

us to feel satisfied about the accuracy of the matters of fact

stated in these reasons which were not the subject of findings

by his Honour.

Section 50 of the Trade Practices Act, so far as

presently relevant, provides:

"50(1) A corporation shall not acquire,

directly or indirectly, any shares in the

capital, or any assets, of a body

corporate if -

(a)

as a result of the acquisition, the corporation would be, or be likely to be, in a position to dominate a market for goods .or services; or

(b)

in a case where the corporation is in a position to dominate a market for goods or services -

(i)

the body corporate or another to that body corporate is, or is likely to be, a competitor of the corporation or of a body corporate that is related to the corporation; and

(ii)

the acquisition would, or

would be likely to,

substantially strengthen

the power of the

corporation to control or

dominate that market.

(3) In this section -

(a)

a reference to a market for goods or

services shall be construed as a

reference to a substantial market for

goods or services in Australia in a

State or Territory; and

(b)

a reference to dominating a market

for goods or services shall be

construed as a reference to

dominating such a market either as a

supplier or as an acquirer of goods

or services in that market."

Section 4E provides:

"For the purposes of this Act, 'market'

means a market in Australia and, when used

in relation to any goods or services,

includes a market for those goods or

services and other goods or services that

are substitutable for, or otherwise

competitive with, the first-mentioned

goods or services."

"Competition" is defined in S. 4(1) as including:

"Competition from imported goods or from

services rendered by persons not resident

or not carrying on business in Australia."

Market definition

We turn to the definition of the "market". Part IV of the Trade Practices Act is designed to foster competition. The role of 9.50 is to maintain competitive markets by

restraining monopolisation and prohibiting mergers that will

produce a non-competitive market.

30.

The identification of the relevant market and the

assessment of dominance, in the sense of market power, cannot

be separated. This point was made by Mason CJ and Wilson J in

Queensland Wire Industries Ptv Limited v The Broken Hi14

Com~anv

Prowrietarv Limited (1989) 167 CLR 177 at 187-8 in

these terms:

"In identifying the relevant market, it

must be borne in mind that the object is

to discover the degree of the defendant's

market power. Defining the market and

a

evaluating the degree of power in that

market are part of the same process, and

it is for the sake of simplicity of

analysis that the two are separated.

Accordingly, if the defendant is

vertically integrated, the relevant market for determining the degree of market power will be at the product level which is the

source of that power ... After identifying

the appropriate product level, it is necessary to describe accurately the parameters of the market in which the

.

defendant's product competes: too narrow a

description of the market will create the

appearance of more market power than in

fact exists; too broad a description will

create the appearance of less market power

than there is."

See also Australia Meat Holdinas Ptv Limited v Trade Practices

Commission [l9891 ATPR 40-932 (Full Court) at 50, 091 and 50,

104.

In the area of restrictive trade practices law it is

impossible to provide an absolute definition of "market". As was observed by Professor Maureen Brunt in her article, "Market Definition Issues in Australian and New Zealand Trade

Practices Litigation" (1990) 18 Australian Business Law Review

"It must be constantly borne in mind that

market definition is but a tool to

facilitate a proper orientation for the

analysis of market power and competitive

processes - and should be taken only a

sufficient distance to achieve the legal

decision. There may be more than one

relevant market for a particular case in

the sense of markets that would attract

liability."

Deane J observed in gueensland Wire at 195 that the

word "market" is not susceptible of precise comprehensive

definition, when used as an abstract noun in an economic

context. He thought that the most that can be said is that

"market" should, in the context of the Act, be understood in

the sense of an area of potential close competition in

particular goods and/or services and their substitutes (cf.

G. & M. Stevens Cartaae Contractors Ptv. Limited [l9771 ATPR

17,445 at 17,460).

In the same case, at 200, Dawson J struck

a cautionary note:

"Too rigid an approach in defining a market .is apt to lead to unrealistic

results.

"

See also the discussion, with reference to some academic

writings, in Mark Lvons Ptv Ltd v Bursill S~ortsaear

Ptv Ltd

(1987) 75 ALR 581 at 588-591.

However, the authorities provide some assistance to

32.

those concerned to define the relevant market in a particular

case. The following passage from the Trade Practices

Tribunal's decision in Re Oueensland CO-o~erative

Millinq

Association Ltd; Re Defiance Holdinas Ltd (1976) 25 FLR 169 ("QCMA") at 190 has frequently been cited. But it is worth

repeating, as it bears on the delineation of the market in the

present

case :

"A market is the area of close competition

between firms or, putting it a little

differently, the field of rivalry between

them ... Within the bounds of a market

there is substitution - substitution

between one product and another, and

between one source of supply and another,

in response to changing prices. So a

market is the field of actual and

potential transactions between buyers and

sellers amongst whom there can be strong

substitution, at least in the long run,

given a sufficient price incentive ...

Whether such substitution is feasible or

likely depends ultimately on customer

attitudes, technology, distance, and cost

and price incentives.

... in determining the outer boundaries of the

market we ask a quite simple but fundamental question: If the firm were to 'give less and charge more' would there be, to put the matter

colloquially, much of a reaction?"

The concept of substitutability of products is

heavily relied upon by the appellants in this case.

Substitutability affects the definition of markets. As Mason

CJ and Wilson J observed in Queensland Wire at 188:

"Section 4E directs that a market is to be

described to include not just the defendant's

product but also those which are

'substitutable' for, or otherwise competitive

with, the defendant's product."

A11 the judgments in the High Court in that case

emphasised the importance of the consideration of

substitutability, as required by S. 4E. Accordingly, the

process of defining a market involves both including products

which compete with the defendant's product and excluding those

which, because of differentiating characteristics, do not

compete.

L

The two main arguments advanced by counsel for the appellants against the correctness of the trial Judge's

delineation of the relevant product market are:

first, that

there are categories of biscuits which are not competitive

with other categories of biscuits; and, second, that there is

competition between certain types of biscuits on the one hand

and certain types of non-biscuit products on the other. The

first matter is said to support the conclusion that there is

not one overall biscuit market but a series of biscuit

markets. The second matter is argued to require a finding, if

aggregation be appropriate, that the market is wider than

biscuits themselves.

As to the first argument, the appellants submit that

his Honour failed to deal with oral evidence to the effect

that retailers do not consider some categories of biscuits to

be competitive with other categories of biscuits.

There was

34.

a new line of biscuit products, take no account of the

possible impact this will have on sales of, or current

marketing practices with respect to, biscuit products in

other categories. For example, retailers consider that

chocolate biscuits compete with other chocolate biscuits, but

not with dry crackers or sweet biscuits. Secondly, there was

evidence that retailers avoid promoting biscuit products of

different manufacturers, within the same category, at the same

time (for example, both a Cadbury and Arnotts chocolate coated

biscuit); but retailers frequently run simultaneous promotions

of biscuits produced by different manufacturers which are

within different categories. For example, an Arnotts

chocolate biscuit promotion may run simultaneously with a

evidence that retailers, when deciding whether or not to stock this evidence is that biscuits are competitive with each other only within well defined categories.

There is evidence each way upon the first matter.

There is certainly evidence which supports the appellants. However, there is also evidence which suggests that retailers do take into account other categories of biscuits when deciding whether to stock a new line of biscuits. This evidence includes the testimony of Mr H Sidler, Senior Merchandise Manager - Food of Woolworths, and M r E R Bender, a consultant who has had a 30 years association with Franklins.

As to the second matter, it is conceded by the Commission that the evidence does establish that retailers

l

avoid the simultaneous promotion of two products within the

same category; but it was argued that this is but one factor

amongst the many which should be considered in defining the

relevant market.

We were referred to a large amount of evidence, both

oral and documentary, concerning the question whether biscuit

manufacturers identify only other biscuit manufacturers as

providing any real degree of competition. There are

references to biscuit manufacturers being aware that biscuits

compete with some non-biscuit products; for example, Weston1s

"Wagon Wheel" product - which is a chocolate coated biscuit

marketed as a confectionery; Nabi.scols "Rum Slice"; certain

after dinner mints which compete with mint flavoured chocolate

biscuits; "Snowballs" which are chocolate coated marshmallow

confections rolled in desiccated coconut and which compete

with sweet biscuits. However, an examination of the evidence

establishes that biscuit manufacturers do not usually concern

themselves with the activities of' the manufacturers of non-

biscuit products. The Arnottsr records which are in evidence

include the sales representativesr regular reports. Those

reports are analysed and summarised at State offices. The

summaries ultimately go to the Arnotts' directors. Other such

records include what are described as "competitive activity

release reports", which are documents kept by Arnotts in which

it identifies products released into the market that, in its

36.

view, compete with its own products. Both the sales concerned with competition, on a day-to-day basis, see themselves as being part of a biscuit industry, within which there is competition but which is little troubled by products sold as confectionery; even products which have characteristics and uses similar to those of some biscuits. The same situation applies to the other two major

representatives' reports and the "competitive activity release

reports" refer almost exclusively to other biscuit products.

manufacturers. Weston keeps monthly sales and marketing

L

reports, monthly action statements and what are described as "business plans". Nabisco maintains similar records. These records relate almost entirely to biscuit products. They

strongly support the conclusion that, essentially, only other biscuit manufacturers are identified by biscuit manufacturers as providing any real degree of competition to their biscuit

products.

The evidence also supports the following

conclusions :

wholesale purchasers - that is, the retailers -

tend not to take into account non-biscuit products

when purchasing, or promoting the sale of, biscuits;

retailers display biscuits in a location separate

to those in which snack foods and confectionery are

displayed;.

in large supermarkets the biscuit buyers are not

necessarily responsible for buying snack foods or

confectionery;

salesmen engaged by manufacturers to sell biscuit

products are generally not responsible for the sale

of their employer's non-biscuit products;

salesmen employed by biscuit manufacturers generally

do not take non-biscuit products into consideration

when selling biscuits; and

suppliers of confectionery and snack foods tend not

to take into account biscuits or their prices when

setting prices for their snack foods and

confectionery.

In evaluating the appellants' submissions relating

to the definition of the product market it is important to (1976) 50 Australian Law Journal at 89-92. Dr Walker pointed out that, in one sense, all goods and services compete for the buyer's custom; and, in that sense, are within the same market. In another sense, most items being distinct in some respect, each item has its own market. In the application of

bear in mind that substitutability involves matters of degree.

the concept to provisions such as s.50, an intermediate

position is appropriate.The Court of Justice of the European

l

Community made a similar point in Hoffmann - La Roche Co AG v it said at 272:

"The concept of the relevant market ...

implies that there can be effective

competition between the products which

form part of it and this presupposes that

there is a sufficient degree of

interchange'ability between all the

products forming part of the same market

in so far as a specific use of such

product is concerned,"

Conversely, in determining, in United Brands v

Commission of the EuroDean Communitieg [l9781 1 CMLR 429, whether other fruits should be excluded from the market which bananas serve, the European Court said at 482:'for the banana to be regarded as forming a market which is sufficiently differentiated from other fruit markets it must be possible for it to be singled out by such special features distinguishing it from other fruits that it is only to a limited extent interchangeable with them and is only exposed to their competition in a way that is hardly perceptible."

It is relevant to recall the observation of Deane J

in Oueensland Wire at 195-196:

"The identification of relevant markets and the

definition of market structures and boundaries

for the purposes of determining whether B.H.Prs

refusal to supply Y-bar to Q.W.I. contravened

s.46(1) involves value judgments about which

there is some room for legitimate differences

of opinion. The economy is not divided into an

identifiable number of discrete markets into

one or other of which all trading activities

can be neatly fitted. One overall market may

overlap other markets and contain more narrowly

defined markets which may, in their turn,

overlap, the one with one or more others. The

outer limits (including geographic confines) of

a particular market are likely to be blurred:

their definition will commonly involve

assessment of the relative weight to be given

to competing considerations in relation to

questions such as the extent of product

substitutability and the significance of

competition between traders at different stages

of distribution."

This observation was made in the course of a

discussion which referred to s.4E of the Act.

Deane J was

making the point that the application of the concept of

substitutability requires the making of a value judgment. The

question of substitutability is not to be disposed of merely

by showing that, upon some occasions, some people consume one

product rather than another or that some products within a

claimed market do not directly compete with some other

products in that market; or do compete with some products

outside that claimed market.

The same point was made, in different language, by

Mason CJ and Wilson J in Queensland Wire at 188. Their

Honours did so by their quotations from Hoffmann-La Roche and

United Brands. Both quotations include words which indicate

that substitutability is a matter of degree:

"sufficient

degree of interchangeability" and "only to a limited extent

interchangeable".

40.

In the present case, emphasis is placed upon the

fact that, upon some occasions, a consumer might select a non- biscuit product ihstead of a biscuit; for example, corn crisps might be served with a savoury dip rather than dry biscuits;

chocolate mints might be offered as an after-dinner sweet,

rather than chocolate biscuits. But the fact that, upon some

occasions, some consumers select one product rather than

another does not establish that the two products are

"substitutable", so as to be within a single market.

No doubt

there are many people who sometimes drink tea and, at other

times, coffee. But if, for example, a particular company

L

dominated the sale of tea within Australia, it would thwart did not dominate the "hot beverage market". The fact is that tea and coffee are distinct beverages, for each of which there is a distinct demand. To adopt the test applied in pCMA, a rise in the price of tea would probably cause few consumers to abandon tea for coffee. It is important to remember that the notion of substitutability adopted in s.4E is one which looks to the market itself, not to the habits of individual consumers. The section speaks of "goods or services that are

the objectives of provisions such as ss.46 and 50 of the Trade

substitutable for, or otherwise com~etitive

with, the first-

mentioned goods or services",

This point emerges clearly from United Brands. The

applicant in that case was a major distributor of bananas.

But it argued that it was not in a dominant position since the

relevant market was not the banana market but the fresh fruit

market, It submitted that bananas compete with other fresh

l

fruit - in the same shops, on the same shelves - at prices

that can be compared and to satisfy the same needs:

consumption as a dessert or between meals. Moreover,

statistics showed that consumer expenditure on the purchase of

bananas dropped during that part of the year when there was a

plentiful supply of other fresh fruit. Yet the European Court

of Justice held that ,it was appropriate to speak of a banana

market. This conclusion was partly based on the fact that

bananas were available throughout,

the whole year, and

therefore substitutability had to be considered on a year- round basis. But it was also based upon the fact that the banana is a distinct product with a distinct demand:

"The banana has certain characteristics,

appearance, taste, soft~ness,

seedlessness, easy

handling, a constant level of production which

enable it to satisfy the constant needs of an

important section of the population consisting

of the very young, the old and the sick. As

far as prices are concerned two FAO studies

show that the banana is only affected by the

prices - falling prices - of other fruits (and

only of peaches and table grapes) during the

summer months and mainly in July and then by an

amount not exceeding 20 per cent. Although it

cannot be denied that during these months and

some weeks at the end of the year this product

is exposed to competiti.on from other fruits,

the flexible way in which the volume of imports

and their marketing on the relevant geographic

market is adjusted means that the conditions of

competition are extremely limited and that its

price adapts without any serious difficulties

to this situation where supplies of fruit are

plentiful, It follows from all these

considerations that a very large number of

consumers having a constant need for bananas

are not noticeably or even appreciably enticed

away from the consumption of this product by

the arrival of fresh fruit on the market and

that even the seasonal peak periods only affect

it for a limited period of time and to a very

limited extent from the point of view of

substitutability. Consequently the banana

market is a market which is sufficiently

distinct from the other fresh fruit market."

See

4 8 3 - 4 8 4 .

In the same way, it may be said that biscuits have

distinct characteristics which set them aside from other

products. As we have pointed out, manufacturers recognise

this. They speak of "the biscuit industry". They concentrate

their competitive attention upon other biscuit manufacturers;

not concerning themselves with those who distribute corn

crisps or chocolates. Retailers recognise this; displaying

biscuits - as a distinct range of products, whether savoury or

sweet - on separate shelves, away from the corn crisps and

chocolates. Most importantly, although some consumers may be

fickle, there must be many for whom no other product provides

an acceptable substitute; who routinely consume biscuits,

throughout the year and with little regard for price

variations or alternatives. We cannot accept the suggestion

that the relevant product market is wider than that for

biscuits.

The argument that the relevant market is narrower than the "biscuit market" has rather more appeal.

Scqe types

of biscuits are not interchangeable with others. A host who

has run out of dry biscuits is unlikely to serve cheese on

chocolate biscuits. But interchangeability of function is

43.

only one element in determining the extent of a market.

It is

not necessary that each product in a particular market serve

precisely the same function as each other. For example, it is

usual to speak of "the motor car market". Yet there is no

real competition between a Mercedes Benz 500SL and a Nissan

Pulsar or between a Ford Fairlane and a Toyota Land Cruiser.

Each vehicle is pitched at a particular segment of the market, to serve people who have particular needs or financial limits. Some people might describe the clusters of vehicles which do

compete with each other as being within a particular sub-

market. But, whether or not that course is taken, it remains

,

.

cars are sold by a limited number of manufacturers, each of

which produces a range of models, has a reputation

transcending any particular product and whose prosperity is

significantly affected by common external factors such as

general economic conditions, labour costs, tariff levels etc.

rational to speak of the "motor car market" in which new motor market" enjoyed by European or Japanese imported cars, or by

the Ford Motor Company.

[And, apropos the earlier point, even

if it appeared that the volume of car sales was affected by

housing interest rates, it would not be sensible, in s.46 or

s.50 terms, to place motor cars within the same market as

houses or mortgage finance.]

It is noteworthy that the industry itself sees

biscuit products, considered as a whole, as constituting a

discrete class of foods. We have already referred to the

4 4 .

internal reports of the three major manufacturers. Even more telling is the practice of "blocking" the biscuit products of one particular manufacturer on supermarket shelves, rather

than dividing the products into categories, each of which

contains the similar products of each stocked manufacturer.

The supermarkets do not place the Arnotts' dry biscuits

alongside the Nabisco dry biscuits or Arnotts' sweet biscuits

with Weston's. All Arnotts' biscuits, for example, are

generally presented together, emphasising the significance of

i

biscuits at the behest of the manufacturers, especially

Arnotts as a "biscuit" manufacturer. The supermarkets "block" to the various suppliers with reference to their total volume of biscuits, not on the basis of separate categories of biscuits. This is significant because shelf space is critical in the sale of biscuits. Speaking generally, Arnotts has 50 percent of biscuit bar space, whilst Weston and Nabisco enjoy about 15 percent and 10 percent respectively.

A further factor telling against the submission that there is a multiplicity of biscuit markets is the form of

,

l

Arnotts' advertising. This advertising is extensive. It has

,

contributed significantly to the market share which Arnotts

enjoys. Arnotts' advertising stresses that there is "no

~

substitute for quality" and Arnotts' name commands strong brand loyalty. Although references are sometimes made to particular products, the focus of the advertising is on the

name "Arnotts"; in connection with biscuits, rather than

45.

particular varieties of biscuits,

l

For the above reasons, we are of the opinion that

the definition of "market" adopted by the trial Judge was

correct.

Dominance

The next question is whether Arnotts is in a

position to dominate the market defined by the trial Judge,

within the meaning of s.50(l)(b) of the Act.

As we have already indicated, Beaumont J found that it was. Much of the material upon which he relied is set out in the seventeen numbered paragraphs which we have already

quoted. Towards the end of his judgment his Honour expressly

referred to some matters which, he thought, indicated

dominance (93 ALR at 707-8):

'Arnotts has had, for many years, a very large

market share. True, Arnotts has some

competition in the supply of biscuits, but not

much. The evidence shows that the members of

the biscuit industry and the members of the

grocery trade, being the 'players' in the

market, act upon the belief that Arnotts is in

a position to exercise, and does exercise, from

time to time, a commanding influence in the

market. The evidence establishes that the size

and strength of Arnotts is such that, in

practice, other entities are unable or

unwilling to offer any significant competition

to Arnotts in the biscuit market in the medium

or long term. Even in the short term, there is

an obvious reluctance to meet Arnotts 'head-on'

or directly. Instead, other suppliers of

biscuits seek to find 'gaps1 or 'nichesf in the

market. All of this conduct is an indication

that Arnotts holds a commanding influence in

the market."

The appellants challenge these findings, contending

that the evidence showed fierce competition within the biscuit industry. Counsel submit that the existence of competition is incompatible with dominance, the essence of which is the

unwillingness of other market participants actively to compete

with the market leader. They also submit that there are no

significant barriers preventing new suppliers of biscuit

6

products commencing business within Australia, that new viable suppliers have in fact recently entered the field and that the major supermarket chains - notably Coles Myer, Woolworths and

Franklins - exercise such power as purchasers of biscuits that they prevent the possession or acquisition of any dominant market power by any supplier, including Arnotts.

The word "dominance" is not defined in the Act.

Its

natural and ordinary meaning is "having a commanding influence

onM: see Trade Practices Commission v Ansett Trans~ort

Industries (O~erations)

Ptv Limited (1978) 32 FLR 305 at 325.

A dominant firm has a high degree of "market power", a term

defined in Queensland Wire.

Mason CJ and Wilson J said at

188:

"Market power can be defined as the

ability of a firm to raise prices above

the supply cost without rivals taking away

customers in due time, supply cost being

the minimum cost an efficient firm would

incur in producing the product ..."

At 200 Dawson J said:

"The term 'market power1 is ordinarily

taken to be a reference to the power to

raise price by restricting output in a

sustainable manner ... But market power

has aspects other than influence upon the

market price. It may be manifested by

practices directed at excluding

competition such as exclusive dealing,

tying arrangements, predatory pricing or

refusal to deal ... The ability to engage

persistently in these practices may be as

indicative of market power as the ability

to influence prices."

His Honour then quoted from Kaysen and Turner, Antitrust

Policv (1959) at 75:

"A firm possesses market power when it can

behave persistently in a manner different

from the behaviour that a competitive

market would enforce on a firm facing

otherwise similar cost and demand

conditions."

Dawson J also referred to pCm at 188-189 and continued:

"Market power is thus the advantage which flows from monopoly or near monopoly ..."

Queensland Wire was concerned with S. 46 of the Act,

but what their Honours said with respect to markets and

market power in that statutory context is relevant also to the

concept of market power underlying 9.50.

The decided cases have stated criteria to which

l

regard may be had in determining whether a participant enjoys

a dominant position in a market. But those criteria vary

according to the facts and circumstances of each case. No

inflexible rule can be laid down, except perhaps in the case

of barriers to entry.

A useful list of criteria was given in QCW at 189:

"Competition is a process rather than a situation. Nevertheless, whether firms compete is very much a matter of the

structure of the markets in which they no doubt the most important is ( 2 ) , the condition of entry. For it is the ease with which firms may enter which establishes the possibilities of market concentration over time; and it is the threat of the entry of a new firm or a new plant into a market which operates as the ultimate regulator of competitive conduct."

operate. The elements of market structure

which we would stress as needing to be

scanned in any cases are these: (1) The

number and size distribution of

independent sellers, especially the degree

of market concentration; (2) The height

of barriers to entry, that is the ease

with which new firms may enter and secure

a viable market; (3) The extent to which

the products of the industry are

characterized by extreme product

differentiation and sales promotion;

(4) The character of 'vertical relationships'

with customers and with suppliers and the

extent of vertical integration; and (5) The

nature of any formal, stable and fundamental

arrangements between firms which restrict bheir

ability to function as independent entities.

4 9 .

Some of the European cases provide assistance in the

resolution of questions of market power and dominance. similar economic concepts.

In Euro~emballaae

Corworation and Continental Can

Com~anv

Inc v Euro~ean

Communities Commission [l9731 CMLR 199

("Continental Can") the European Court appears to have taken

into account, on the question of dominant position: market

share for the products in question; the size of the new unit

created by the merger in relation to the size of competitors

in the market; the economic strength of customers in !relation

to the new unit and potential competition either from

manufacturers of the same products situated in other

geographical markets or from manufacturers of other products

situated in the common market.

United Brands, a case of high barriers to entry,

adopted what was said in Continental Can. There the factors which, when taken together, were said to give United Brands an unchallengeable ascendancy over its competitors: its market share; the diversity of its sources of supply; the homogeneous nature of its product; its distribution system; its marketing system and publicity campaigns; the diversified nature of its operation and its vertical integration. The Court said that "dominant position" relates to a position of economic strength enjoyed by an undertaking which enables it

to prevent effective competition being maintained on the

relevant market by giving it the power to behave to an

I

appreciable extent independently of its competitors, customers

and, ultimately, its consumers. The European Court pointed

out that, speaking generally, a dominant position derives from

a combination of factors: the company's structure; the

situation on the market so far as competition is concerned;

whether a trader has succeeded in winning a large market share

(a trader does not have to eliminate all opportunity for

competition to be in a dominant position); and barriers to

entry, which may include any exceptionally large capital

*

investment required for the creation and running of a

competitive business enterprise. The decision stressled that

it is the cumulative effect of these matters which determines

whether an enterprise has a dominant position in the relevant

market.

Hoffman-La Roche was also a barrier to entry case.

The European Court acknowledged that the importance of market share might vary from one market to another; but it slaid that the view might legitimately be taken that very large market

shares are in themselves, save in exceptional circumsltances,

evidence of the existence of a dominant position. The Court

went on at 275:

"An undertaking which has a very large market share and holds it for some time, by means of the volume of production and the scale of the supply which it stands for - without those

having much smaller market shares being able to

meet rapidly the demand from those who would

like to break away from the undertaking which

has the largest market share - is by virtue of

that share in a position of strength which

makes it an unavoidable trading partner and

which already because of this secures for it,

at the very least during relatively long

periods, that freedom of action which is the

special feature of a dominant position."

In Hoffmann-La Roche the Court rejected reliance on

mere market share, saying that, on the facts of that case,

this might just as well result from effective competitive

behaviour as from a position which ensures that the company

can behave independently of competitors. But the Court

thought it always to be relevant to consider the relationship

between the market share of the undertaking concerned and that

of its competitors, especially those of the next largest, the

technological lead of an undertaking over its competitors, the

existence of a highly developed sales network and the absence

of potential competition; the first because it enables the

competitive strength of the undertaking in question to be

assessed, the second and third because they represent in

themselves technical and commercial advantages and the fourth

because it is the consequence of the existence of obstacles

preventing new competitors from having access to the market.

A little more should be said about the concept of

barriers to entry. In Queensland Wire Mason CJ and Wilson J

said at 189:

"A large market share may well be evidence

of market power ... but the ease with

which competitors would be able to enter Professor F.M. Scherer has written, 'significant entry barriers are the sine qua non of monopoly and oligopoly, for ... sellers have little or no enduring power over price when entry barriers are non- existent': Scherer, Industrial Market Structure and Economic Performance, 2nd ed. (1980) p. 11. Barriers to entry may be legal barriers - patent rights, exclusive government licences and tariffs for example.' Barriers to entry may also be a result of large 'economies of scale'. Where the economies of scale in a market are such that the minimum size for an efficient firm is very large relative to the size of the market, it may be that potential competitors will be dissuaded from entering the market by the apprehension that only one firm would

"A properly designed and conducted survey

may overcome all these problems. The

number of witnesses will be considerably

reduced. Probably it should only be

necessary to call the persons responsible

for designing and administering the survey

and an expert witness to verify the design

and methodology employed. The survey, if

so verified, should provide objective

results, with no opportunity for those

questioned to be briefed as to their

answers. Equally, the respondents to the

survey will give answers that are

realistic in the sense that they will not

be exposed to lengthy cross-examination as

to the rationality of their beliefs, a

matter which is surely irrelevant and

which if raised can only go to undermine

the continued holding of the belief

itself. In general, therefore, such

evidence will be more representative, more

objective, and hence more trustworthy and

reliable. This is not to say that survey

evidence is infallible. It is only as

good as the state of the science ... and

as the quality of the particular survey

used. Nevertheless statisticians require

little convincing that such evidence will

give considerably more reliable results

than that traditionally employed."

See also Zi~wo

Manufacturina CO v Roaers Im~orts

216 F.Supp.670 (1963) where, at 683-684, ~einberg

J of the

United States District Court said this:

"Even if the surveys did not fit within this exception, well reasoned authority justifies their admission under the

following approach: the determination admissibility of a survey. Necessity in this context requires a comparison of the probative value of the survey with the evidence, if any, which as a practical matter could be used if the survey were excluded. If the survey is more valuable, then necessity exists for the survey, i.e., it is the inability to get 'evidence of the same value' which makes the hearsay statement necessary. When, as here, the state of mind of the smoking population (115,000,000 people) is the issue, a scientifically conducted survey is necessary because the practical alternatives do not produce equally probative evidence. With such a survey, the results are probably approximately the same as would be obtained if each of the 115,000,000 people were interviewed. The alternative of having 115,000,000 people testify in court is obviously impractical. The alternatives of having a much smaller section of the public testify (such as

that a statement is hearsay does not end

the inquiry into admissibility; there must

still be a further examination of the need

for the statement at trial and the

circumstantial guaranty of trustworthiness

surrounding the making of the statement.

eighty witnesses) or using expert

witnesses to testify to the state of the

public mind are clearly not as valuable

because the inferences which can be drawn

from such testimony to the public state of

mind are not as strong or as direct as the

justifiable inferences from a scientific

survey.

M

These two quotations touch also our second reason: both of the alternative methods of proving consumers' habits and attitudes are unacceptable. One theoretical possibility,

in a case like the present, would be for a party to call such

of the 1,200 respondents to the Roy Morgan survey as were

contactable. This course would have the advantage of

providing a fairly selected group of witnesses; subject to any

distortion which might be caused by difficulties in locating

respondents. But it would add enormously to the cost and

duration of a trial.

The second possibility would be for a party to call

evidence from a lesser number of selected witnesses. This

course was taken in Ritz. The plaintiff there called 152

members of the public.

The majority of these witnesses were

stopped in a public place by a representative of the plaintiff

and questioned as to the significance to them of the word

"Ritz". It seems that those who gave answers favourable to

the plaintiff's case were asked to give evidence. Those who

did not, were not. As a result, the evidence of these persons

was of negligible value. All that it established was that,

with the expenditure of sufficient effort and money, 152

people could be found somewhere in Australia who claimed to

109.

associate the word "Ritz" with the plaintiff.

The 152

that, as McLelland J noted at 215, there was "no ground in the

evidence for any extrapolation on a statistical basis, or on

the basis of any mathematical or logical probability, of the

views of the 'public' witnesses (or any selection from them)

as representing the views of the relevant class of the

Australian public or a significant section of that class".

witnesses were not a fair sample of the general public; so of persons interviewed; for all the judge knew, the persons

who associated the word "Ritz" with the plaintiff may have

c .

been a tiny minority. The tender of such partisanly selected

evidence was an absurdity; yet it was a major reason why the

trial took over seven months.

A further possibility is that there will be no

evidence about matters such as public recognition of names or use of a particular name or trade mark would constitute misleading conduct or cause confusion, the court must make its own assessment of the situation. The position is similar where the question is whether one product is substitutable for another. But information is preferable to intuition. Where the state of public knowledge of, or attitudes to, some subject is a relevant factor in the court's adjudication of an issue, it is better to admit than to preclude evidence on those matters.

attitudes to products. Perhaps this would not matter greatly.

110.

For the above reasons, we would not uphold the respondent's objection in point of principle to the Roy Morgan

I

survey evidence. But there remain other objections, related expert to report on the reliability of the Roy Morgan report,

to the nature of this particular survey. First, it is said

that the training given to the interviewers was insufficient.

One of the three interviewers who was called said that his

training amounted to the completion of a trial questionnaire

and a thirty minute interview with someone from Roy Morgan.

Mr E Brinkley, a statistical consultant attached to the

thought that "fairly substantial" training was necessary.

He

l

had in mind a two or three day training course and supervision

of interviewers during their "first few" interviews.

Secondly, Mr Brinkley made criticisms of the form of many of

the questions. We need not set them all out. It is

I

ambiguities. For example, the interviewees were asked to

identify things that they "sometimes" ate between meals. But

no guidance was given as to the meaning of "sometimes". Some

respondents may have mentioned things eaten two or three times

a week; some, things eaten once a year. As substitutability

is a concept of degree, the difference is significant.

sufficient to say that many of the questions contained words "not available". But it was not explained whether this meant available in the home or available at the local supermarket; so, in terms of market behaviour, it is difficult to see what use may be made of the answers. Mr Brinkley also

111.

noted the difficulties of recall posed by some questions; for

example, a question which invited respondents to list the

foods eaten by themselves and all members of their households

over the preceding seven days. He commented that the best way

of obtaining such information is to ask interviewees to keep a

diary during the period surveyed.

In addition to the criticisms made by Mr Brinkley,

counsel draw attention to an exhibit containing the comments

of some of the interviewers. These comments contain

references to the length of the interview - it involved many

questions other than those commissioned by the appellants -

the repetitious nature of many of the questions, including the

subject questions, and the difficulty interviewers experienced

in maintaining the interviewees' interest. Another exhibit, a

bundle of reports from 111 interviewees, suggests that more

than half the interviews took more than 20 minutes, some over

50 minutes.

As indicated, Beaumont J accepted the admissibility

of the Roy Morgan report. But he was impressed with the

respondent's criticisms of the questions. He held that "it

would not be safe to give any real weight to the results of

the survey". We agree with this view. We add that we are

also troubled by the paucity of the training given to the

interviewers, by their reports as to the attitudes of

interviewees and the difficulty of maintaining interviewee

interest over such a long period.

112.

We have already indicated our opinion that

Australian law should follow the American lead in acknowledging that market survey evidence may play a useful

role in cases such as the present.

In so doing, we do not

mean to suggest that survey evidence will always, or even

usually, be decisive. It will be merely one element in the

overall picture, its importance varying from one case to

another: see the stimulating recent article by an American practitioner, Peter Weiss, "The Use of Survey Evidence in

Trademark Litigation:

Science, Art or Confidence Game?" in

(1990) 80 Trademark Reporter at 71-86.

But, for reasons which

this article emphasises, it is also important to follow the of the survey. We speak, of course, of a survey tendered at a final hearing. A less stringent attitude may be appropriate at an interlocutory hearing where the issue is whether there is a serious issue to be tried.

We have already quoted the criteria listed in the

Judicial Conference Handbook. They seem to be equally

appropriate for Australia.

In our opinion, any exercise of

discretion, as under 0.33 r.3, to admit survey evidence should

depend upon compliance with those criteria. Where survey

evidence which does not satisfy those criteria is admitted, it

would ordinarily be entitled to little weight. That is the

present case.

Surveys are expensive. So it may be prudent for

113.

parties in future cases to raise these matters with their opponents and the Court before any survey is carried out:

see, by way of warning, Associated News~a~ers

~ l c

v Insert

Media Ltd [l9901 2 All ER 803 at 805-806. The course which we suggest was taken in an early case in this Court, Grevnell

Investments Ptv Ltd v Hunter Doualas Ltd:

see para.15-140 of

the Australian Trade Practices Reporter where the directions

are set out. If the form of the relevant questions is agreed

by the parties after expert advice, or settled by the Court,

the results ought not to suffer the fate of the subject

report.

Other market survev re~orts

The parties tendered other market survey reports.

August 1980 regarding confectionery. Another was a survey by

One was a report of a survey made by Rowntree Hoadley in reports were commissioned by Arnotts.

All of these reports were admitted into evidence as

business records - cf. Shoshana - but the trial Judge placed

little weight upon them. He commented:

"In no case was the person who

commissioned the report called. Nor was

the person who carried out the survey

called. The persons whose views were

sought in the course of the survey were

not called. In these circumstances, it

would be unsafe to rely upon the opinions

or conclusions expressed in these reports.

In my view, these are entitled to little

weight.

"

We would not regard the failure to call the

interviewees as affecting the weight of these various reports. tendering market survey evidence. And the criteria adopted by the Judicial Conference of the United States, which we have already suggested are appropriate for Australian use, do not include the calling of all of the interviewers. But we agree with the Judge's criticism of the lack of evidence as to how these various surveys were conducted. Even more importantly, the reports do not provide real assistance on any relevant issue. Questioned on this, counsel for the appellants offered one example of the utility of the reports. They referred to the finding of the 1980 Rowntree Hoadley survey that 64.4% of all interviewees regarded "Kit Kat" as a "biscuit" or "chocolate-coated biscuit". The question included in the survey invited the interviewees .to choose between two

descriptions of the product:

"chocolate-coated bar" and

"chocolate-coated biscuit". As counsel for the respondent says, given that the description "chocolate-coated bar" is hardly appropriate, it is not surprising that many people

chose the alternative. But the answer proves nothing about

market definition. Rqwntree Hoadley has always marketed "Kit

Kat" as confectionery.

The "Kit Kat" question was offered only as an example. But it seems to be the best example which counsel

115.

can muster. That fact strengthens our impression that there

is nothing in these reports which assists the appellants1

case.

Mrs Svmonds' evidence

Finally, in relation to evidentiary matters, the

appellants complain of the trial Judge's reaction to evidence led from Mrs Nicole Symonds, a solicitor employed by the firm acting for the appellants. Beaumont J dealt with her evidence

in this way:

"Mrs. Symonds, a solicitor employed by during the course of the trial, she purchased from several retail outlets in Sydney many items of biscuits, snack foods, confec,tionery and breakfast cereals. More than one thousand items were tendered through Mrs. Symonds; The items were purchased in an endeavour to comply with an instruction, given to her by the solicitor with the conduct of Arnottsl defence, 'to purchase biscuits and any like products'.

It is not suggested that Mrs. Symonds has should be given to her views as a consumer to indicate the range of processed foods available in this general area.

any experience in the biscuit industry.

Accepting that Mrs. Symonds may be regarded as a consumer of processed foods,

I am of the view that, because of Mrs.

Symonds' professional association with evidence should be given little weight.

Even if this factor were not present, Mrs.

Symondsl evidence was necessarily limited

in its scope. It cannot, for instance,

tell us the volume of the trade in the

products tendered, in what areas they are

marketed and over what period they have

been marketed. Without knowing these

details, very little could be inferred

from Mrs. Symonds' testimony."

We agree with these comments. We add that it is not

apparent to us that there was any need to call Mrs Symonds at

all. We appreciate that the appellants wished to prove the

range of products available to retail customers and the type

of stores where they might be purchased. But we would have

expected that, if Mrs Symonds had prepared a list of her

I

I

admission. The purchases could then have been tendered. If

the respondent declined to make an admission, Mrs Symonds

might have been briefly called to prove the purchases. The

list and the purchases could have been tendered through her.

purchases, the respondent would have made an appropriate the appellants had wished the trial Judge to examine the purchases, he could have done so at his convenience, not necessarily in court time. As it was, Mrs Symonds was in the witness box for most of three days. Her evidence extended over 185 pages of transcript. This was partly because senior counsel for the appellants took the course of asking her numerous unnecessary questions. For example, counsel spent many hours taking her descriptions of the packaging of each of the products which she had purchased; something which the trial Judge was capable of seeing for himself. Mrs Symonds gave evidence on such esoterica as her reasons for preferring

salted cashews and walnuts to pecan nuts and the order of the

various layers in a mint stick. The course taken by counsel

I

for the respondent was equally irresponsible. Senior counsel

spent hours cross-examining the witness on such minutiae as

the progress of her trolley through the stores where she made

her purchases, the precise location of various items, who

helped her place the goods in the trolley etc.

At the trial, as before us, counsel for the

appellants sought to use Mrs Symonds' evidence to show what

products were substitutable for biscuits. The argument is

that, Mrs Symonds having been instructed "to purchase biscuits

and any like products", her selection constituted evidence of

the available "like products". Counsel contend that "like

products" are substitutable products, so the relevant market

must include all of the items which she selected.

Leaving aside its other difficulties, this line of

argument depends entirely upon Mrs Symonds' assessment of what constitutes a "like productw to biscuits. But, in what sense, "like"; in composition, appearance, taste, nutritional value,

calorific value, price? Or some only of those matters; and,

if so, which of them? Without a definition of the word

"like", the exercise was fundamentally flawed.

But, even if

there had been a precise definition, Mrs Symonds was a

solicitor working on the case, She was hardly a typical

consumer. Even assuming that the views of a single consumer were worth having on the issue of substitutability, without

118.

reflecting on Mrs Symondsf sincerity it was ludicrous to

expect his Honour to give weight to the views on that issue of

a solicitor involved in the case. She could not possibly put

herself in the position of a "typical consumer", if such a

person exists. His Honour was plainly correct in declining to

place any weight on this evidence.

We are of the opinion that most of the complaints

made by the appellants in respect of the trial Judge's rulings

on evidence are ill-founded. To the limited extent that we

are persuaded that his Honour wrongly rejected evidence, that

evidence is not shown to be significant. Even if it were

admitted, and taken into account, it would make no difference

to the view we have formed about the principal issues in the

case. Accordingly, there is no justification for a new trial.

The a~~lication

to call fresh evidence

Shortly after we reserved judgment on the appeal,

their clients desired to file a notice of motion seeking leave

to reopen their case in the appeal and tender fresh evidence.

the solicitors for the appellants informed the Court that returnable on 2 November 1990. The motion was made pursuant to 0.52 r.36 of the Rules of Court. The Commission opposed the motion. After hearing argument, we dismissed the motion, indicating that our reasons would be included in our reasons for judgment in the appeal generally. What follows are those

reasons.

The evidence which the appellants asked the Court to

receive was of facts in existence at the time of the hearing before Beaumont J. But the appellants said that evidence of these facts was not available to them despite their

conscientious efforts to obtain it. The relevant evidence

consists of certain paragraphs (9 and 15(b)) of a draft

affidavit of a Mr G E M Falk, a solicitor in the employ of a

Sydney firm of solicitors, Phillip Parbury and Associates, and

annexures

"D", "E", "F", "H" and "I" thereto, Annexure "DM

g .

is a facsimile dated 15 May 1989 from H J Campbell Pretty & of Phillip Parbury & Associates. Campbell Pretty is a marketing research company which, together with The Ball Partnership (Australia) Pty Limited and Mattingly Pty Limited, two advertising and marketing companies, was employed by United Biscuits Holdings Plc or United Biscuits (UK) Limited (referred to collectively as "United Biscuits") in 1989 to undertake research and prepare reports concerning the possible entry of United Biscuits into the Australian biscuit market. United Biscuits is an international company with its head

office in England.

It is one of the world's principal

manufacturers and suppliers of biscuits. Annexure "E" is a

facsimile sent by Campbell Pretty to Mr Parbury on 8 May 1989

enclosing a facsimile from United Biscuits to Campbell Pretty

dated 5 May 1989. Annexures *Fw and "Hw are facsimiles, dated

15 May 1989 and 23 May 1989 respectively, from United Biscuits

120.

to Mr Parbury. Annexure "Iw is a facsimile dated 23 May 1989 from Anderson Hughes Ball W.C.R.S. Limited to Phillip Parbury

l

& Associates.

In support of the motion, counsel for the appellants

argued that if these documents were admitted into evidence

they would establish that:

prior to the date of the judgment of Beaumont J in Australia and had incurred substantial costs - at least $100,000 - in the preparation of market research reports with respect to such a launch;

by 8 May 1989 United Biscuits had decided to market

biscuits in Australia, intended that millions of

dollars would be invested by it in that marketing

and was preparing for a.major product launch of

biscuits in Australia.

Counsel for the appellants submitted that:

other evidence which was admitted at the trial establishes that United biscuits is one of the world's largest manufacturers of biscuits and is a

corporation far larger than Arnotts;

the fact that United Biscuits planned to launch a

121.

range of ,biscuits in Australia, after assessing the

market, is conclusive, or at least highly

significant, evidence of the lack of significant

barriers to entry;

the proposed evidence directly traverses several

allegations made in the amended statement of claim;

if the evidence had been available, the trial Judge

would have been compelled to a finding to the

contrary to that which his Honour came; namely, that

there "is no evidence either direct or

circumstantial, that the party in question " - that

is, United Biscuits - " proposes, or for that matter

does not propose to launch its products in Australia

at this stage". Hence, so it was argued, his Honour

would have found that there were no significant

barriers to large scale entry; and, therefore, that

Arnotts could not be dominant.

The Court has power in its discretion to receive

further evidence, either on affidavit or by oral examination:

see 9.27 of the Federal Court of Australia Act and 0.52

r.36(5), which requires that the evidence which a party wants

the Court to receive on the hearing of an appeal be given by

affidavit.

Counsel for both the appellants and the Commission

agreed that, in determining whether fresh evidence should be

introduced on the hearing of an appeal, the established

principle is that such evidence should not be allowed unless

it is almost certain that, if the evidence had been available

and had been adduced at the trial, an opposite result would

have been reached by the primary judge. Reference was made to

the judgment of Dixon J in

v Holmeg (1948) 76 CLR 632 at

"But the evident purpose of all of them is to existence of the fact it tends to prove that a finding to the contrary, if it had been given, would, upon the materials before the court, appear to have been improbable if not unreasonable."

ensure that new trials will not be granted

because of fresh evidence unless it places such

a different complexion upon the case that a

reversal of the former result ought certainly

to ensue. The fact which the new evidence

tends to prove, if it does not itself form part

of the issue, must be well nigh decisive of the

state of facts upon which the issue depends.

The only relevant material in annexures "D", "E",

"F", "H" and "I" to the draft affidavit of Mr Falk are

statements of a hearsay nature. Moreover, they were each

"made or obtained for the purpose of, or in contemplation of,

any judicial ... proceeding" within the meaning of s.7C(1) of

the Evidence Act. Accordingly, none of them would be

admissible under Part IIIA of that Act as business records.

Counsel for the appellants accepted that position, but argued

that Part IIC of the Evidence Act

1898 (NSW) applied to

permit their reception into evidence. In that connection,

123.

they relied on s.79 of the Judiciarv Act 1903 which provides:

" 7 9 .

The laws of each State or Territory,

including the laws relating to procedure, be binding on all Courts exercising federal jurisdiction in that State or Territory in all cases to which they are applicable."

evidence, and the competency of witnesses,

shall, except as otherwise provided by the

Counsel argued that 55.79 of the Judiciarv Act

required in this case 'the application of Part IIC of the New the annexures to be received into evidence. Counsel sought to meet s.l4CF(1) of the New South Wales Evidence Act, which restricts the admissibility of business records, with an argument that it has a substantially different meaning from s.7C(1) of the Commonwealth Evidence Act and does not render the annexures inadmissible in this case. Section 14CF(1) provides :

"Notwithstanding section 14CE, a statement made

or obtained for the purpose of, or in

contemplation of, a legal proceeding or any

other legal proceeding arising out of the same

or substantially the same facts is not

admissible.

"

Counsel contended that the subject documents arose

out of a legal proceeding different from the principal

proceeding because it related to compliance with subpoenas

issued in the principal proceeding.

124.

We need not pause to examine the correctness of this

argument. It is plain that there is no room for the are not in precisely the same terms is not to the point. The Commonwealth Evidence Act makes extensive provision for the admission into evidence of business records and effectively covers that field. It has "otherwise provided" within the

application of Part IIC of the New South Wales Act in this

case. The Commonwealth Evidence Act addresses the

admissibility of business records. The fact that the

meaning of s.79 of the Judiciarv Act:

cf. DeQutv Commissioner

of Taxation v Moorebank Ptv Limited (1988) 165 CLR 55 at 64. provisions of the New South Wales Evidence Act relating to the admissibility of business records.

In Su~etina

Spender J considered the interaction of

with respect to business records. His Honour held that s.92

of the Queensland Act, insofar as it relates to documents

which come within Part IIIA of the Commonwealth Evidence Act,

is inconsistent with that Part and is, to that extent, invalid

by virtue of the operation of s.109 of the Constitution.

the Commonwealth Act and the Queensland Evidence Act 1977, conclusion on our construction of s.79 of the Judiciarv Act; rather than on the notion of inconsistency within the meaning of s.109 of the Constitution.

125.

Unless the Court were to resort to 0.33 r.3 - a

course plainly inappropriate in relation to such controversial and imprecise material as this - none of these documents would be admissible. And what remains, paras.9 and 15(b) of Mr

Falkfs draft affidavit, has no separate probative value.

There are other reasons which led us to dismiss the

appellantsf motion. The evidence before Beaumont J

established that United Biscuits was contemplating a test

launch in Australia of its biscuit products. But it did not

establish whether United Biscuits, even if it did carry out a

test launch, would or would not make a general launch of

biscuit products into the Australian market or, if it did,

whether such a launch would have the effect of placing any

constraint upon Arnotts. The fresh material which the

appellants sought to adduce in evidence before us adds little,

if anything, to the inferences which may be drawn from the

material already before the trial Judge, in particular exhibit

85. Certainly this further material falls far short of

esgablishing, even with the aid of existing evidence, the

conclusions for which the appellants contend.

At its highest, this additional evidence shows no

more than that, in mid 1989, United Biscuits contemplated products intended to be marketed, the scale of the launch or, of course, its likely success, In particular, it says nothing

launching some of its biscuits into the Australian market.

126.

about the likely effect, if any, of the United Biscuits launch

on Arnottsf position in the Australian market.

In short, if

this additional evidence were admitted, it would not meet the

test propounded by Dixon J in

v Holmes.

Conclusion

The appeals should be dismissed.

I certify this and the one hundred and twenty five (125)

preceding pages to be a true copy of

the Reasons for Judgment of

the Court.

Associate:

"(---z

Date :

29 November 1940

Counsel for the First and

Second Appellants:

C A Sweeney, QC and

C P Comans

Solicitors for the First and

Second Appellants:

Clayton Utz

Solicitors for Third and

Fourth Appellants:

Minter Ellison

Counsel for the Respondent:

B C Oslington, QC,

D G Staehli and

M R J Ellicott

Solicitor for the Respondent:

Australian Government

Solicitor

Counsel for George Weston Foods

Limited:

P M Jacobson

Solicitors for George Weston

Foods Limited:

Allen Allen & Hemsley

Dates of Hearing:

30 July 1990,

1, 2, 3, 6, 7, 8, 9

August 1990,

2 November 1990.

Actions
Download as PDF Download as Word Document


Cases Citing This Decision

8

Keller v R [2006] NSWCCA 204
Cases Cited

8

Statutory Material Cited

0

Wong v Silkfield Pty Ltd [1999] HCA 48