The speech at issue is expression by fans related to a sporting event, to all aspects of the game, all the participants in the game, and all the circumstances surrounding the game-a broad new category we can call "cheering speech." Cheering speech can be directed at teams, players, coaches, officials, executives, administrators, or other fans. It can be in support of one's own players and team, against the opposing players and team, or even critical of one's own players and team. It can be about events on the field or it can target broader social and political issues surrounding the game, the players, or sport in general.
Howard M. Wasserman,
Cheers, Profanity, and Free Speech
, 31 J.C. & U.L. 377
Available at: http://ecollections.law.fiu.edu/faculty_publications/69