Bulls America, LLC ("RBA")', incorporated in Arizona, and The Great Bull Run,
<br /> LLC ("GBR")2, incorporated in Massachusetts. At these events, between 12 and 21
<br /> bulls are sent stampeding down a quarter-mile long, fenced-in track towards
<br /> upwards of 1,000 people who pay to participate in the event.3 The participants
<br /> attempt to run in front of or dodge the 1,500 pound animals hurtling towards them.
<br /> As would be expected of this inherently dangerous activity, runners are often
<br /> injured; in fact RBA's 2012 event resulted in several hospitalizations.4 For those
<br /> who do not wish to run in the stampede, "spectator" tickets are available for
<br /> purchase which allows both the opportunity to watch the stampede as well as to
<br /> purchase the available concessions including food and beer.5 In addition to the
<br /> actual animal stampede, several other activities take place at these events to
<br /> entertain the participants and spectators, such as a food fight called the "tomato
<br /> royale."6
<br /> The Animal Welfare Act and Regulations
<br /> Congress enacted the Animal Welfare Act ("AWA") to ensure the humane
<br /> care, treatment, handling and transportation of animals exhibited to the public,
<br /> among other animals, and tasked USDA with enforcement of the law. See, e.g., 7
<br /> U.S.C. § 2131. Any person who exhibits or plans to exhibit an animal covered by
<br /> the AWA must possess a valid license and must comply with the rules, regulations
<br /> and standards promulgated by the agency. 7 U.S.C. § 2134. The penalty for
<br /> conducting regulated activities without the necessary license or for violating any
<br /> other AWA rule, regulation, or standard is a civil penalty of up to $10,000, which is
<br /> 1 Attachment 1, Arizona Corporate Commission Corporate Inquiry (as of May 22, 2013).
<br /> 2 Attachment 2, Commonwealth of Massachusetts Certificate of Organization (filed January 17,
<br /> 2013).
<br /> 3 http://www.thegreatbullrun.com/faq/ (last accessed May 29, 2013); "Running of the Bulls USA in
<br /> Cave Creek, Arizona (It's Back)!," available at http://youtu.be/zSlJnmxgsjs (last accessed May 29,
<br /> 2013).
<br /> 4 Meredith Somers, It's no Pamplona, Spain, but the Great Bull Run will thunder into Virginia, THL
<br /> WASHINGTON TIMES, May 14, 201.3 (accessible at http://www.washingtontimes.coin/news
<br /> /2013/may/14/in-the-spanish-spirit-the-great-bull-run-will-thunn. There are also several videos on
<br /> YouTube.com that demonstrate the dangerous nature of these events. For instance, in "Cave Creek,
<br /> AZ Running with the Bulls," a woman is shown being hurled to the ground by a charging hull.
<br /> http://www.youtube.com/watch?v=FkWWa3SVOyw at 1:56. Acutely aware of the "inherent risks" to
<br /> personal safety that these events entail, participants in GBR events must sign a waiver of liability
<br /> before participating. See http://www,thegreatbullrun.com/wp-content/uploads/2013/03/GBR
<br /> _Virginia_�Waiverl.pdf The waiver details the injuries associated with the stampeding such as
<br /> "scrapes, bruises, sprains, nausea and cuts" as well as "broken bones, torn ligaments, concussions,
<br /> deep lacerations or puncture wounds...damage to internal organs, spinal injuries and paralysis,
<br /> stroke, heart attack and death." Id.
<br /> 5 http://www.thegreatbullrun.com/faq/
<br /> G http://www.thegreatbullrun.com/tomato-royale/
<br /> 2
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