Matchroom Boxing Limited v. Paul

Background

Matchroom Boxing Limited and Edward John Hearn sued Jake Paul for defamation. Glenn Feldman later intervened as a plaintiff and filed a separate complaint asserting a defamation claim. The plaintiffs alleged that, during a September 20, 2022 online interview, Paul said that Feldman was being paid by Matchroom Boxing to favor Matchroom fighters and described the conduct as corruption and a repeated crime. Matchroom Boxing, Hearn, and Feldman denied those accusations.

The statements concerned two boxing matches. Matchroom Boxing promoted the April 30, 2022 Taylor-Serrano fight at Madison Square Garden, and Paul’s company, MVP Management LLC, promoted Amanda Serrano. Paul attended promotional events and the fight in New York under a co-promotion agreement. Matchroom Boxing also promoted the August 2022 Usyk-Joshua fight in Saudi Arabia, which Feldman judged. Paul was in Puerto Rico when he made the challenged statements. The complaints alleged that the statements were widely republished, including in the Southern District of New York.

Paul’s Motion

Paul moved under Federal Rule of Civil Procedure 12(b)(3) to dismiss for improper venue, under Rule 12(b)(2) for lack of personal jurisdiction, and under Rule 12(b)(6) for failure to state a claim. His Rule 12(b)(6) argument addressed Matchroom Boxing’s ability to sue under New York Business Corporation Law § 1312(a), which can prevent an unauthorized foreign corporation doing business in New York from maintaining an action there.

Venue

The court denied the motion to dismiss for improper venue. Under 28 U.S.C. § 1391(b)(2), venue is proper where a substantial part of the events giving rise to a claim occurred. Although Paul made the allegedly defamatory statements while in Puerto Rico, the court concluded that material events bearing a close connection to the claims occurred in the Southern District of New York.

The court emphasized that the alleged defamation concerned supposed bribery connected to Feldman’s judging of the Taylor-Serrano fight at Madison Square Garden. Paul also traveled to New York to promote that fight, including attending a press conference, conducting media activities, attending another press conference and the weigh-in, and attending the fight itself. The court concluded that venue was proper in the Southern District of New York.

Personal Jurisdiction

The court denied the motion to dismiss for lack of personal jurisdiction. The complaints relied on New York Civil Practice Law and Rules § 302(a)(1), which permits jurisdiction over a nonresident who transacts business in New York when the claim arises from that business activity.

The court found that Paul’s contacts went beyond the brief visits or communications that may be insufficient in a defamation case. Through MVP Management, he entered into an agreement to promote a New York boxing match; he traveled to New York on multiple occasions to promote it; his company received income from the fight; and his allegedly defamatory statements concerned that match. The court held that these facts were sufficient at this stage to show that Paul transacted business in New York and that the defamation claims arose from that conduct.

The court rejected Paul’s argument that his activities could not support jurisdiction because he acted only as a representative of MVP Management. It explained that New York does not apply the fiduciary-shield doctrine to defeat jurisdiction under its long-arm statute, so a corporate officer’s or employee’s New York contacts may be considered even when made in a corporate capacity.

Failure to State a Claim

The court denied Paul’s Rule 12(b)(6) motion based on New York Business Corporation Law § 1312(a). Paul argued that Matchroom Boxing was doing business in New York without authorization and therefore could not maintain its defamation action. The court explained that this statutory defense generally requires proof that the corporation engaged in a regular and continuous course of conduct in New York, and that a defendant relying on the defense bears the burden of establishing it.

Because Paul relied on evidence outside the Complaint, including deposition testimony from jurisdictional discovery, the court would not consider that evidence to resolve the defense on a pre-answer Rule 12(b)(6) motion. The Complaint alleged that Matchroom Boxing was organized under United Kingdom law, had its principal place of business in the United Kingdom, and promoted the Taylor-Serrano fight in New York. The court concluded that those allegations did not establish that Matchroom Boxing had engaged in a regular and continuous course of business in New York without authorization. Accordingly, the court denied this basis for dismissal.

Disposition

The court denied Defendant’s motion to dismiss the Complaint. It directed the Clerk of Court to terminate the motion, docket number 51.