Matchroom Boxing Limited v. Paul
1:22-cv-08178
| S.D.N.Y. | Sep 30, 2024Background
- Matchroom Boxing Limited and Edward John Hearn (UK-based boxing promoters) allege Jake Paul (social media influencer and boxing promoter, residing in Puerto Rico) defamed them by claiming they bribed a boxing judge, Glenn Feldman, to fix the outcomes of the Taylor-Serrano (NYC, April 2022) and Usyk-Joshua (Saudi Arabia, August 2022) fights.
- Feldman, the judge implicated, joined the suit as an intervenor, also alleging defamation.
- The allegedly defamatory statements were made by Paul in a September 2022 interview with iFL TV, conducted while he was in Puerto Rico; the statements were disseminated online.
- Paul moved to dismiss the lawsuit for improper venue (under FRCP 12(b)(3)), lack of personal jurisdiction (FRCP 12(b)(2)), and failure to state a claim (FRCP 12(b)(6)), arguing Matchroom cannot sue because of its corporate status in NY.
- The court completed jurisdictional discovery before considering the motion to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper Venue | Venue is proper where the Taylor-Serrano fight occurred and was promoted | Venue improper: Paul lives in PR, made statements from PR, few personal ties to NY | Venue proper (substantial events - fight, promotion - in SDNY) |
| Personal Jurisdiction | Paul transacted business in NY by promoting fight, contractual obligations | Lacks sufficient contacts; only made statements from PR; promotion was through MVP company, not personally | Sufficient contacts—Paul purposefully availed himself by promoting fight in NY |
| Matchroom’s Capacity to Sue (1312) | Matchroom not "doing business" in NY under BCL 1312(a); one fight isn’t enough | Matchroom regularly does business in NY without registration, so cannot sue | No basis to dismiss on pleadings; not clearly "doing business" in NY |
Key Cases Cited
- Daniel v. Am. Bd. of Emergency Med., 428 F.3d 408 (2d Cir. 2005) (venue proper if substantial events/omissions occurred in district)
- Kreutter v. McFadden Oil Corp., 71 N.Y.2d 460 (N.Y. 1988) (long-arm jurisdiction applies even to corporate agents acting solely in official capacity)
- Fischbarg v. Doucet, 9 N.Y.3d 375 (N.Y. 2007) ("transaction of business" analysis for personal jurisdiction focuses on quality of contacts)
- Talbot v. Johnson Newspaper Corp., 71 N.Y.2d 827 (N.Y. 1988) (jurisdiction hinges on sufficient nexus between NY contacts and cause of action)
- Highfill, Inc. v. Bruce & Iris, Inc., 50 A.D.3d 742 (N.Y. App. Div. 2d Dep’t 2008) ("doing business" under BCL Section 1312 requires regular and continuous conduct)