In Record v. Reason (1999) 73 Cal. App. 4th 472, the Second District explicitly considered the issue of whether a particular activity was a "sport" such that primary assumption of risk should apply to bar plaintiff's negligence claim. In Record the court considered the activity of "tubing" behind a motorboat. After extensively reviewing cases applying primary assumption of risk to a variety of activities, the court generally surmised that "compiling all of the distinguishing factors, it appears that an activity falls within the meaning of 'sport' if the activity is done for enjoyment or thrill, requires physical exertion as well as elements of skill, and involves a challenge containing a potential risk of injury." (Id. at p. 482.) The court concluded that holding on to a tube being pulled behind a boat involved "combining centrifugal force with a white-knuckled grip" and therefore fell within the meaning of "sport." (Ibid.) In Record v. Reason, the plaintiff was injured when he fell off an inner tube while being towed behind a motor boat. He sued the boat's driver for negligence. The trial court granted summary judgment for the defendant based on primary assumption of the risk, and denied the plaintiff's request to amend the complaint to allege a claim of intentional or reckless conduct based on his declaration that he had asked the defendant to drive the boat slowly since this was his first time on this particular type of tube. The Court of Appeal affirmed the trial court's denial of leave to amend, stating, "Although the defendant may have intended the actions he undertook in maneuvering the boat, there is no evidence that he intended to throw the plaintiff into the water and cause him to injure his back. Nor was this consequence so inevitable as to transform the defendant's actions in maneuvering the boat from negligence to recklessness." (Id. at p. 486.) Thus, the court concluded that the proposed amendment did not allege a viable claim. (Ibid.)