The third module, Module 3, was the second module with a twin focus: on the routine reporting of politics and on the question of whether illicit deals were done between politicians and press proprietors.

On the question of whether illicit deals had been done, there is no disguising the fact ...

I'm not sure that it's for us to answer that question, sir, but one thought one has is that, given that the investigation was very properly secret, indeed I think "covert", in police terms, it might have occurred to them that they risked sending the wrong message if ...

But it is certainly not conclusive.

So we would say that those matters undoubtedly have their place in the history, but one has to be cautious in the extent to which one can say that they are current examples of the culture, practices and ethics of the press.

Going on ...

Yes. Well, one must accept that it's not conclusive, but the reflection which occurred to me as you were speaking, sir, is simply this, that with all acquisitions of personal data, whether it is by a debt collecting agency or a local authority or something, it's inherent in ...

Yes.

Yes.

There is a limit, yes, but I think one has to assess the Information Commissioner's statements in this context. First of all, that the Information Commissioner, with his department, has a full-time job of listening out for this sort of thing, and I think indeed one or other -- I ...

Yes.

I'm grateful. Indeed, as you, I'm sure, appreciate, the team is a bit like an iceberg. I may be above the surface, but there's a great deal below. They do most of the work, I am pleased to say.

One aspect we've dealt with in writing ...

Sir, if I can borrow some terminology from the Tour de France, I am, I think, in the position of the lanterne rouge, the last man in the field.

Whilst Mr Jay, consistently supported by his team, like Mr Bradley Wiggins, of course sports the maillot jeune for consistently leading ...

The vote is to start a little earlier this afternoon. I apologise if that disturbs people's lunches.

Let me enquire.

I'm the last man, I think, sir. I think I shall be about 40 minutes, so I'm in your hands as to whether --

Thank you.

Thank you, sir. I haven't seen him. I just wanted to explain why -- and as the Inquiry has just heard, Mr Michel's position remains that he didn't make any threats of any sort.

Yes.

I wanted to say something in light of Mr Lamb's evidence.

It's simply this: we received Mr Lamb's note of the meeting on 21 October whilst the Inquiry was sitting at 10.30 this morning. The note of his conversation with Mr Clegg we saw on the ...

Thank you very much, Mr Brown.

Mr Brown, the only question I want to ask you is this: did you have the conversation with Lord Mandelson that he said that you had in the evidence I've just read to you?

The questions are from Mr Jay:

"Question: "The allegation is, or rather the evidence was from Mr Murdoch that Mr Brown said or uttered the words 'declare war on News International' or words to that effect. From your own knowledge, Lord Mandelson, can you assist us as to whether there ...

I will do that.

This is Day 74 in the afternoon.

He was. He was asked about whether or not there was a call between you and Mr Murdoch shortly after the Sun had announced that it was no longer going to support the Labour Party on 30 September 2009, I think it was.

Day 74.

It's 21 May.

That's a transcript of the evidence that Lord Mandelson gave.

Yes.

I think you're probably familiar with this. It's behind tab 8 of your bundle. If you'd like to go to it, it's ...

Mr Brown, my name is Rhodri Davies. I appear for News International.

Yes, I have.

The position is you may recall that Lord Mandelson gave some evidence about that. Mr Brown hasn't addressed that and I think he ought to be given the opportunity to deal with it, or at least, we would like to know what he says about it.

It relates, I'm afraid, to the disputed call between Mr Brown and Mr Murdoch.

We've been in correspondence with the Inquiry about this and the answer we've received is that correspondence -- the Inquiry's correspondence with witnesses is confidential. Now, it does appear to us that that simply cannot apply in this instance, and given that the vast majority of witnesses have ...

It's simply this. We would like to see the questions which those -- which some of the witnesses are answering in the cases where they have not quoted the questions in their witness statements. What has happened is this: most of the witnesses who have given evidence recently have been ...

Might I raise a point, sir?

Mr White will explain, sir.

Thank you very much. Thank you, sir.

Because of course as you've explained, you yourself, I think, were never in receipt of any such improper conduct?

But you understand, I'm sure, Dr Cable, that without knowing who is supposed to have been threatened and when, it's extremely difficult for Mr Michel or anyone else to respond to the allegation?

And that, as I understand it, was between the intervention notice and the discussion you had with the Telegraph journalists?

Sorry, I thought you were -- I hope this isn't confused. I thought you were explaining when you came to hear of it.

Yes, but do we know when that was?

Are you willing or able to say when the threat is supposed to have been made?

That's between 4 November and 3 December?

Within what period?

Are you willing to say when you received that report?

Do I have this right, you are not prepared to identify the source of that report to you?

All right. You went on to say that you had received reports that Mr Michel had made veiled threats to, I think, Liberal Democrat politicians, and you said there was one case where you received that report directly; is that right?

I understand that. All I'm asking you to agree, Dr Cable, is that there's no indication here that News Corp wanted this bid politicised. They were being told it was, but that wasn't what they wanted to hear.

Yes.