all future events, and the future of horse racing generally. This is having a direct effect on the commerciality of the Applicant.
Wider Impact on the Applicant ’ s Business – Commercial
62.
The commercial success and longevity of the Applicant, and horse racing more widely, directly depends on the revenue from sponsors, audiences and broadcast partners and all commercial activity. As set out above, the Applicant invests significantly in equine welfare, which is critical to its reputation and therefore commercial longevity. The actions of AR threaten to damage that reputation. If horse racing is no longer seen as safe and entertaining, then people may no longer pay to watch it, either in person or broadcast. This would reduce gate receipts as well as TV broadcast fees. Further, disruption to events has the potential to cause significant reputational harm to the Applicant and also to racing more widely. Approximately 85,000 people are directly and indirectly employed in horse racing in Britain. The industry contributes approximately £4.1 billion to the economy in the United Kingdom. As a result of the Aintree Incidents and the 11 May Meeting, the Applicant engaged Pinsent Masons LLP ( “ PM ” ) and Counsel. PM has obtained witness statements from Mr. White and Ms. Starkey, which records their respective experiences of the Aintree Incidents and the various meetings and discussions that have taken place with the known Respondent and AR, including the 11 May Meeting.
63.
64.
65.
66.
67.
Service of Documents
68.
The Applicant also seeks an order against persons unknown. As I have already said, other than Daniel Kidby, the Applicant does not know the identities of the individuals who affiliate themselves with AR, or who intend to carry out the specific acts the Applicant seeks to prevent from happening. On this basis, it is not possible for the Applicant personally to serve the relevant documents on the Second to Eighth Defendants (i.e. the Persons Unknown), and the Applicant has made an application for permission to serve those Defendants by alternative means.
69.
13
JDR2 / 23
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