FORMULA ONE LICENSING B.V. et al v. John or Jane Does 1-200 et al, flsdc:1:2024cv21597

Clothing, namely, pants, jeans, jerseys, jumpers, swimwear, beach cover-ups, brassieres, camisoles, cardigans, lingerie bodices, children's jumpers, children's sleepwear, children's one-piece garments, leggings, tracksuits, coats, waistcoats, stadium vests, bathing suits, bath robes, scarves, shirts, belts, neckties, aprons, sweatshirts, suspenders, skirts, shawls, gloves, waterproof jackets, waterproof pants, jackets, blazers, sports jackets, pullovers, sleeveless pullovers, sweaters, underwear, garters, socks, stockings, trousers, shorts, pajamas, bibs not of paper, knitted sweaters, wrist bands as clothing, kimonos, vests, suits for infants and children, t-shirts, singlets, uniforms, dresses, motorists' clothing, namely, jumpsuits and jackets; footwear, namely, shoes, flip flops, slippers, sandals, boots, waterproof footwear, sports shoes; headgear, namely, hats, baseball caps, knitted caps, headbands, bandanas, headscarves, sun visors, cap peaks * ; none of the aforementioned goods intended or adapted for use in an orthopedic or therapeutic setting, for orthopedic or therapeutic muscle or joint support, or as orthopedic or therapeutic compression or anti-embolism products *;

Entertainment services, namely, organizing in the nature of providing passenger rides on race circuits for motorsport fans in sports cars and racing cars driven by professional drivers, without competing;

[EDUCATION SERVICES, NAMELY, PROVIDING WORKSHOPS IN THE FIELD OF COMMERCE; PROVIDING OF TRAINING IN THE FIELD OF COMMERCE;] ENTERTAINMENT, NAMELY, PROVIDING ENTERTAINMENT ACTIVITIES IN THE NATURE OF MOTOR RACING COMPETITIONS; SPORTING AND CULTURAL ACTIVITIES, IN THE NATURE OF MOTOR RACING COMPETITIONS;

SERVICES FOR PROVIDING FOOD AND DRINK; BAR SERVICES; CAFÉS; CAFETERIAS; CANTEEN SERVICES; CATERING OF FOOD AND DRINKS; SELF-SERVICE RESTAURANTS; SERVICES PROVIDED BY RESTAURANTS; SNACK BAR SERVICES;

CLOTHING, namely, SHIRTS, [ PANTS, COATS, DRESSES; FOOTWEAR, ] HEADGEAR, namely, HATS, CAPS; [ ANORAKS; APRONS; ] [BABIES' PANTS; ] ; BASEBALL CAPS; [ BATH ROBES; BATH SANDALS; BATHING SUITS; BATHING TRUNKS; BEACH CLOTHING, namely, SWIMWEAR, BEACH COVER-UPS AND FLIP FLOPS; BEACH SHOES; BELTS; BERETS; ] [BIBS NOT OF PAPER;] [ BLAZERS; LINGERIE BODICES; BOOTS ; BOOTS FOR SPORT; BRACES FOR CLOTHING; BRASSIERES; CAMISOLES; ] CAPS; [ CARDIGANS; ] CHILDREN'S WEAR, namely, JUMPERS, OVERALL SLEEPWEAR, PAJAMAS, ROMPERS AND ONE-PIECE GARMENTS; [ CLOTHING OF IMITATION LEATHER, namely, SHIRTS, PANTS, SHORTS; CLOTHING OF LEATHER, namely, SHIRTS, PANTS, SHORTS; ] COATS; [ DRESSING GOWNS; EAR MUFFS; ESPARTO SHOES OR SANDALS; FROCKS; GLOVES; ] HATS; [ HEADBANDS; HEADSCARVES; HOODS; HOSIERY; ] JACKETS; [ JEANS; JERSEYS; JUMPERS; KIMONOS; ] KNITWEAR, namely, KNIT [ DRESSES, KNIT ] CAPS, POLO KNIT TOPS; [ LAYETTES; LEGGINGS; LEISURE SHOES; MITTENS; MONEY BELTS; MOTORISTS' CLOTHING, namely, JUMPSUITS; NECK SCARVES; NECKTIES; ] OUTER CLOTHING, namely, COATS, JACKETS, [ PARKAS; OVERALLS; OVERCOATS; PANTS; PARKAS; ] PEAK CAPS; [ POCKET SQUARES; PULLOVERS; PAJAMAS; ] RAINWEAR; READY MADE CLOTHING, namely, SHIRTS, [ PANTS, SHORTS; SANDALS; SARIS; SCARVES; SHAWLS; SHIRTS; SHOES ; SHORTS; SHOULDER SASHES TO BE WORN OVER CLOTHING; SHOULDER WRAPS; SINGLETS; SKIRTS; SLIPPERS; SMOCKS; SOCKS; SPORTS JERSEYS; SPORTS SHOES; STOCKINGS; SUITS; SUN VISORS; ] SWEATERS; [ SWIMSUITS; TABARDS; ] TEE-SHIRTS; [ THREE-PIECE SUITS; TIGHTS; TRACKSUITS; TROUSERS; UNDERWEAR; UNIFORMS; ] VESTS; [ WAISTCOATS; ] WATERPROOF CLOTHING, namely, WATERPROOF JACKETS [ AND PANTS; WRISTBANDS ];

[ LEATHER AND IMITATION LEATHER; TRUNKS AND TRAVELLING BAGS; ] UMBRELLAS, [ PARASOLS, ATTACHÉ CASES; BACKPACKS; ALL PURPOSE SPORT BAGS; BAGS FOR PACKAGING OF LEATHER; BAGS FOR TRAVEL; ] BEACH BAGS; BEACH UMBRELLAS; [ LEATHER SHOULDER BELTS; BOXES OF LEATHER OR LEATHER BOARD; BRIEFCASES; BUSINESS CARD CASES; CASES, OF LEATHER OR LEATHER BOARD; COIN HOLDERS IN THE NATURE OF WALLETS; CREDIT CARD HOLDERS; DISPATCH BAGS; DOCUMENT WALLETS; GARMENT BAGS FOR TRAVEL; GYM BAG; HANDBAGS; WALKING STICK HANDLES ; HAVERSACKS; KEY CASES; LUGGAGE FOR TRAVELLING; LUGGAGE TAGS; NET BAGS FOR SHOPPING; POCKET WALLETS; POUCHES OF LEATHER FOR PACKAGING; PURSES; RUCKSACKS; SATCHELS; SCHOOL BAGS; ] REUSABLE SHOPPING BAGS; [ TEXTILE SHOPPING BAGS; SLINGS BAGS FOR CARRYING INFANTS; SPORT AND LEISURE BAGS; ]LEATHER STRAPS; [ SUIT CARRIER; SUITCASES; TOILETRY BAGS SOLD EMPTY; ] TOTE BAGS [; TRAVEL AND GROOMING CASES SOLD EMPTY; TRAVELLING BAGS; LUGGAGE TAGS MADE OF LEATHER; TRAVELLING SETS COMPRISING LUGGAGE, GARMENT BAGS FOR TRAVEL, VANITY CASES SOLD EMPTY; TRAVELLING TRUNKS; VALISES; VANITY CASES SOLD EMPTY; WALKING-STICKS; WHEELED SHOPPING BAGS ];

Apparatus and instruments for conducting, switching, transforming, accumulating, regulating or controlling electricity; apparatus for recording, transmission and reproduction of sound and images; cash registers; calculating machines; data processing equipment; computers; digital media, namely, compact discs, DVDs and other digital recording media featuring auto racing; fire-extinguishing apparatus; mechanisms for coin-operated apparatus; downloadable computer software for database management; magnetic data carriers, namely, prerecorded magnetic data carriers featuring auto racing and blank magnetic data carriers; recording discs, namely, blank record disks; electric batteries for vehicles; loudspeakers; amplifiers; satellite dishes; precision measuring apparatus, namely, bevels; navigation apparatus for vehicles; projection apparatus, namely, video projectors; radios; vehicle radios; remote control apparatus, namely, remote controls for radios, televisions, stereos; television apparatus; high definition television apparatus; cameras for photography; apparatus for recording, transmitting, editing, mixing and reproducing of sound and images; apparatus for reading digital music, namely, optical readers, digital audio players and portable media players; data processing apparatus; speed measuring apparatus for photography; distance measuring apparatus; apparatus for verifying data of cards magnetically encoded; time recording apparatus; telephone apparatus; personal digital assistants (PDAs); earphones; earphones with hearing protection; earphones for cellular telephones; headsets for telephones; headsets for cellular telephones; headsets with hearing protection for cellular and mobile phones; headphones; headphones with hearing protection; headphones for cellular telephones; stereo headphones; music headphones; in-ear headphones; noise cancelling headphones; noise cancelling headsets for cellular and mobile phones; noise reduction headsets for cellular and mobile phones; noise reduction headphones; wireless headphones; wireless headsets for cellular and mobile phones; cases for headphones; cases for headsets for cellular and mobile phones; cases for ear plugs; automatic indicators of low pressure in vehicle tires; rechargeable batteries; binoculars; electronic computer notebooks; electronic diaries; electronic agendas; directional compasses; cables, electric; automated teller machines; cinematographic cameras; video cameras; camera accessory cases; camera accessory straps; batteries; protective helmets for sports; video game cassettes; mouse pads; photovoltaic cells; computer chips for integrated circuits; answering machines; converters, electric; cords for sunglasses; cords for glasses; cellular telephone straps; smoke detectors; slides for photography; video game discs; liquid crystal displays; electric door devices that facilitate remote opening and closing, namely, remotes for doors; electric apparatus for remote ignition of vehicles; portable electronic storage devices, namely, disk drives, computer hardware for transferring, storing and transporting electronic data between electronic storage devices, and blank USB flash drives; ticket dispensers, namely, dispensers that count and measure output for use with tickets; hands free kits for phones; data processing equipment, namely, scanners; carrying cases adapted for cellular telephones; containers for contact lenses; exposed photographic films; photography flash bulbs; photocopiers; cellular telephone covers; karaoke recorders; karaoke players; gloves for protection against accidents; holograms, namely, hologram apparatus; magnets; decorative magnets; document printers for use with computers; speed indicators; alarms; cassette players; portable cassette players; portable CD players; CD players; mini digital versatile disc players; DVD players; MP3 players; contact lenses; eyeglasses; video recorders; computer carrying cases; windsocks for indicating wind direction; pressure gauges; downloadable electronic maps; money counting and money sorting machines; dictating machines; electronic machines for reading credit cards; money counting machines; money dispensing machines, namely, automatic teller machines (ATM); pressure measuring apparatus; microphones; modems; computer hardware, namely, monitors; downloadable and recorded computer programs for operating computer monitors; portable electronic storage devices, namely, blank electronic storage memory media devices and USB computer security key; solar panels for the production of electricity; computer screens; plasma video screens; protective films adapted for computers, tablets, and mobile telephones; flat panel display screens; downloadable ringtones for cellular telephones; downloadable graphics for cellular telephones; magnetic encoded identification bracelets; central processing units, namely, processors; data processors; downloadable and recorded software for games of chance machines, reel games and interactive slot machines; downloadable game software; recorded game software; recorded computer programs for video games and audiovisual games; downloadable and recorded computer programs for video games and audiovisual games; computer databases, namely, electronic databases in the field of auto racing recorded on computer media; downloadable electronic publications, namely, books, newspapers, and magazines in the field of motor sports; portable radios; data processing equipment, namely, computer mouse; audio-receivers; video-receivers; pressure indicators; clothing for protection against fire; semi-conductors; simulators for the steering and control of vehicles; home cinema systems comprised of televisions, video recorders, audio speakers, headphones, audio receivers, video receivers, television receivers, audio amplifiers, audio decoders, video decoders, electrical audio and speaker cables and connectors, CD players, CD recorders, DVD players, DVD recorders, digital media players, video projectors, antennas, power conversion devices, power converters, and power inverters; downloadable computer software for editing, downloading, transmitting, receiving, creating, playing, extracting, encoding, decoding, displaying, storing and organizing text, graphics, images, and electronic publications; downloadable computer software, particularly software for transmission, recording, reproduction, visualization, organization, management, manipulation and reviewing messages, text, images, archives, audio-visual and audio and video content, and other data to facilitate communications between multiple users via the global computer network; ear plugs for divers; blank electronic chip cards; memory expansion cards; smart cards, namely, integrated circuit cards; magnetically encoded credit cards; identity cards, magnetic; magnetic encoded prepaid mobile telephone calling cards; blank smart cards containing a computer chip with integrated circuit; computer keyboards; keyboards for cellular telephones; facsimile machines; smartphones; portable telephones; electronic pocket translators; transceivers; cathode ray tubes; x-ray tubes not for medical purposes; anti-glare glasses; protection goggles, namely, safety goggles; sunglasses; computer disc drives; clothing for protection against accidents, irradiation and fire; video discs, video tapes, magnetic tapes for tape recorders, magnetic discs, DVDs, floppy disc drives, optical discs, mini compact discs, mini -discs, CD-ROMs, all the aforementioned being blank; video discs, video tapes, magnetic tapes for tape recorders, magnetic discs, DVDs, floppy disc drives, optical discs, mini compact discs, mini -discs, CD-ROMs, all the aforementioned being pre-recorded with music, sound and images and animation; camcorders; video telephones; anti-dazzle shades, namely, visors for motorsport helmets; integrated circuits; encoded smart cards containing programming used to make purchases; magnetically encoded credit cards; magnetically encoded debit cards; magnetically encoded charge cards; pre-paid telephone calling cards, magnetically encoded;

Adhesives for stationery and household purposes; bookbinding material; printers' type; printing blocks; photographs; printed instructional and teaching materials in the field of auto racing; artists' materials, namely, brushes, pastels, pens, pencils, canvas and painting sets; plastic films for packaging; paper, cardboard and goods made from these materials, not included in other classes, namely, books, magazines, brochures and newspapers in the field of auto racing; stationery; paintbrushes; printed matter, namely, journals, handbooks, booklets, magazines, newsletters and books featuring auto racing; stickers; diaries; scrapbook albums, coin albums, stamp albums, event albums; sticker albums; photograph albums; office requisites, except furniture, namely, staplers, staple removers, adhesive tape dispensers, correcting fluid for type, paper trimmers, hand operated paper hole punches, electric paper hole punches, rubber bands, letter trays, ink stamps; drawing materials for blackboards; document files; flags of paper; entry tickets; notepads; ball-point pens; pens; fibre-tip writing pens; felt-tip writing pens; paper bags; garbage bags of paper and plastics; boxes of cardboard and paper; pencil cases; decalcomanias; calendars; paint boxes for use in school; folders for papers; advertisement boards of paper and cardboard; posters; booklets in the field of motor sports; adhesive tapes for stationery and household purposes; printing blocks; tablecloths of paper; newspapers; adhesive tape dispensers; stationery, namely, writing cases; bumper stickers; pamphlets in the field of auto racing; paper coasters; ball-point pen sets; pencil sets; drawing sets comprised of drawing pads, drawing pencils, and drawing rulers; writing paper; desk pads; baggage claim check tags of paper; paper labels, not of textile; paper coffee filters; collectible photographs of sports personalities; commemorative stamp sheets; passport holders; paper clips; rubber erasers; staples for offices; writing chalks; printed timetables; writing instruments; plastic sheets and films for wrapping and packaging; plastic and paper bags for wrapping and packaging; correction fluids for documents, printing blocks, and type; lithographs; pencils; coloring pencils; books in the field of motor sports; children's activity books; address books; printed books and reviews, featuring information about sports personalities and sports events; autograph books; geographical maps; electric and non-electric typewriters; electric and non-electric pencil sharpeners; stationery marker pens; printed teaching materials in the field of auto racing; handkerchiefs of paper; writing cases in the nature of pen and pencil cases; lithographic works of art; calendars, namely, personal organizers; palettes for painters; paper banners; paper; self-adhesive paper for notes; food wrapping paper; writing paper; copying paper; gift wrapping paper; toilet paper; luminous paper; entry tickets; protective covers for entry tickets; passes, namely, entry tickets; plastic film for preserving foodstuffs for household use; paperweights; paper clasps, namely, paper clips; binder clips; fountain pens; boxes for pens; holders for cheque books; event programs; colouring books; drawing books; square rulers for drawing and measuring; paintings, framed and unframed; blank flip charts; printed flip charts; printed score charts for motor sports; printed charts for recording motor sports scores; felt-tip colouring pens; comic books; magazines being periodicals in the field of motorsports; postage stamps; stamps, namely, seals for the office; bookmarkers; envelopes; bookends; stands and containers for office articles, namely, desk stands and holders for paper, paperclips, pens, pencils and ink; photograph stands; stands for pens and pencils; inking pads; note cards; invitation cards; cardboard and plastic display cards that are printed and stamped; greeting cards; postcards; thumbtacks; tissues of paper; writing ink; admission entry tickets; place mats of paper; towels of paper; paper wipes for cleaning; paper towels for other cosmetic uses; napkins of paper for removing make-up; printed bank checks, namely, traveler's cheques;

Clothing, namely, pants, jeans, jerseys, jumpers, swimwear, beach cover-ups, brassieres, camisoles, cardigans, lingerie bodices, children's jumpers, children's sleepwear, children's one-piece garments, leggings, and tracksuits; footwear; headwear, namely, hats, caps; coats; waistcoats; marking vests, namely, stadium vests; bathing suits; bath robes; hats; caps being headwear; boots; scarves; shoes; shirts; headbands; clothing belts; neckties; aprons; sweatshirts; braces as suspenders for clothing; skirts; shawls; bandanas (neckerchiefs); knitted caps; gloves; waterproof jackets and pants; waterproof footwear; jackets; blazers; sports jackets; pullovers; sleeveless pullovers; sweaters; underwear; garters; socks; stockings; trousers; shorts; pyjamas; bibs, not of paper; knitwear, namely, sweaters; wrist bands as clothing; kimonos; vests; suits; suits for infants and children; shoes; t-shirts; singlets; sandals; uniforms; dresses; cap peaks;

Telecommunications access services; telecommunications consulting; news agency services for electronic transmission; leasing of broadcast apparatus for external broadcasting, namely, leasing of telecommunication equipment; leasing of telecommunications installations; communication by radio; communication by telephone; communication by telegraph; providing telecommunications connections to a global computer network and to internet and databases; radio and television broadcasting of programs relating to sports and sports events; cable television program broadcasting; radio broadcasting; distribution and transmission of data relating to interactive entertainment and interactive competitions via analogue television, digital television, cable television, satellite television, pay-per-view television, interactive television, interactive entertainment and interactive competitions; television broadcasting; rental of telecommunication equipment; rental of facsimile machines; rental of telephones; rental of access time to global computer networks featuring music streaming websites on the internet via a global computer network and via wireless electronic communication devices; rental of access time to global computer networks via a database server center; rental of access time to global computer networks featuring computer databases; electronic transmission of e-mail; providing online discussion groups for transmission of messages among computer users via the internet and on any wireless electronic communication network, namely, electronic transmission of information posted to usenet newsgroups and discussion groups via a global computer network; providing access to data communication servers and real-time chat forums, namely, providing internet chatrooms; providing connections for telecommunications with a global computer network, the internet, and with data banks; audio, video, radio, television, internet, and wireless broadcasting; communication by mobile telephone; transmission of information via data processing equipment; internet service provider services via the internet and via any wireless electronic communication network; telecommunication services dedicated to retail sales by means of interactive communications with customers, namely, providing electronic transmission of credit card transaction data and electronic payment data via a global computer network; telecommunication connectivity services for receiving and exchanging information, messages, images and data; teleconferencing services; mobile telephone services; videotext and teletext data transmission services; radio, telephone or other means of electronic communication, namely, paging services; providing access to websites offering digital music on the internet via a global computer network and via wireless electronic communication devices; providing access to a multi-user network system, namely, providing telecommunications connections featuring information relating to betting and money games and internet-based services and other global networks; providing access to a global computer network and interactive communication technologies for access to private and commercial purchasing and ordering services; providing Internet access to computer bulletin boards and chat rooms in real time via a global computer network; providing access time to a global computer network and interactive communication technologies, namely, providing multiple-user access to a global computer network for access to private and commercial purchasing and ordering services; providing multiple-user wireless access to the internet featuring computer bulletin boards and chat rooms in real time via a global computer network; providing rental of access time to a global computer network, namely, the internet and via wireless electronic communication devices; telecommunication services, namely, providing fibre-optic network services; electronic data transmission of websites via telecommunication networks; multimedia telecommunication services, namely, electronic data transmission; cable television transmission and broadcasting; transmission of computer information, websites information, and data via telecommunications network; information transmission via communication satellite, microwave and by electronic, digital and analogue means; transmission of information via mobile telephone, telephone, facsimile machine and telematic sending of information; transmission of digital information by cable, wire and fiber; streaming of audio, visual, and audiovisual material via a global computer network; electronic message transmission; computer aided transmission of messages and images; transmission of digital music via the internet and via any wireless electronic communication network; delivery of digital music by electronic transmission, namely, transmission of digital music via telecommunications; delivery of digital music by electronic transmission, namely, transmission of digital music via streaming websites; transmission of commercial internet pages online and via wireless electronic communication devices, namely, providing internet access; facsimile transmission; on-line transmission of electronic publications, namely, electronic transmission of documents via computer terminals and electronic devices; real-time streaming of video and audio material via the internet; real-time streaming of digital music via mobile telephones; transmission and dissemination, namely, broadcasting of television and radio programs via the internet and via any wireless electronic communication network; telecommunication services, namely, simulcasting and webcasting broadcast television over global communications networks, the internet and wireless networks and webcasting of film, sound and video recordings; simulcasting and webcasting of interactive educational and entertainment products, interactive compact disks, CD-ROMs, computer programs and computer games, namely, transmission of sound, video and information; satellite transmission; services to provide access to multiple users to a computerized global information network and databases for the transmission and dissemination of any type of information, image and sound, namely, providing multiple user wireless access to the internet; distribution of data and audio visual images via the internet;

Sporting and cultural activities, namely, organizing community sporting and cultural events; educational services, namely, conducting classes, seminars and workshops in the field of auto races; entertainment services, namely, arranging and conducting of auto races; conducting entertainment exhibitions in the nature of auto races; providing live musical performances; providing non-downloadable playback of audio and video in field of auto races via global communications networks; providing online computer games; entertainment in the nature of light shows; providing an on-going radio and television program in the field of auto racing; providing training in the use of race cars; providing training in the form of courses, seminars, and workshops in the field of auto racing; online betting and casino gaming services via the internet and on any wireless electronic communication network; radio and television coverage of sports events, namely, a continuing sports show broadcast over television and radio; timing of sports events; night club services; ticket agency services for motor sport events; entertainment services in the nature of production of films and television shows; interactive entertainment, namely, providing temporary use of non-downloadable interactive games; practical training, namely, providing training in the field of auto racing; providing educational information in the field of auto racing via on-line from a computer database and via the internet and via any wireless electronic communication network; entertainment information, namely, providing information relating to sports and sporting events, online, from a computer database and via the internet and via any wireless electronic communication network; rental of sound and picture recordings for entertainment purposes; rental of video and audio-visual entertainment installations; providing digital music via internet, namely, providing online music, not downloadable; organization of community sporting and cultural events and sports activities; organizing, arranging, and conducting motor sport events; organization of exhibitions for cultural and educational purposes; organization of sports competitions; arranging contests; arranging of beauty contests; organization of computer games competitions; operating lotteries; arranging and conducting of concerts; arranging conferences and training workshops in the field of auto racing; amusement park services; party planning; providing sports facilities; providing facilities for recreation activities; production of movies and television shows featuring animated cartoons for the cinema and television; production of programs for radio, television and videotape; production, presentations, namely, showings, distribution and rental of film recordings and sound and video recordings; provision of digital music, namely, providing online music, not downloadable; publication of books; publication of books and electronic online journals on-line, namely, blogs about auto racing; reservation of entry tickets to sports and entertainment events, namely, arranging for ticket reservations for shows and other entertainment events; betting and gaming in the nature of casino gambling, on-line on the internet or on any wireless electronic communication network services relating to sports; customer reception services featuring providing access tickets for sports and entertainment events, namely, entertainment ticket agency services; editing services, namely, post-production editing services in the field of music, videos and film; entertainment services in the form of public viewing of live and delayed broadcast of sports events, namely, entertainment services in the nature of live sports, namely, a live continuing program featuring sports accessible by means of television, radio, web-based applications, mobile phone applications and ongoing television programs in the field of sports; entertainment services in connection with sports events, namely, organizing motor sport events; providing information in the field of sporting events and entertainment; hospitality services, namely, planning, arranging, organizing, conducting, and hosting parties and social entertainment events for others in conjunction with sporting events; audio and video recording services; electronic games services provided by means of the internet and mobile telephones; ticket reservation services for entertainment, sporting and cultural events; prize draws, namely, lotteries; provision of entertainment, amusement, recreation, and sports facilities; translation services; photographic services, namely, photographic and video capture; provision of sports information relating to statistical information, namely, providing a website containing information relating to auto racing, sports team information, player statistics and sports news; news agencies, namely, gathering and dissemination of news;