United States District Court Southern District of New York
Case 1:11-cv-08215-KMW Document 34 Filed 09/24/12 Page 1 of 178 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Jon Jones, Gina Carano, Frankie Edgar, Matt Hamill, Brian Stann, Zuffa, LLC d/b/a Ultimate Fighting Championship, Don Lilly, Shannon Miller, Danielle Hobeika, Beth Hurrle, Donna Hurrle, Steve Kardian, Joseph Lozito, Erik Owings, Chris Reitz, and Jennifer Santiago, Plaintiffs, No. 11 Civ. 8215 (KMW)(GWG) -against- FIRST AMENDED COMPLAINT Eric T. Schneiderman, in his official capacity as Attorney General of the State of New York, Defendant. Plaintiffs, on knowledge with respect to their own acts, and on information and belief with respect to all other matters, challenge the constitutionality of New York’s law regarding the performance of “combative sport” and allege as follows. I. INTRODUCTION 1. Mixed martial arts is one of the fastest growing spectator sports in the United States. Mixed martial arts involves bouts between highly trained athletes skilled in various martial and combat arts, including karate, jiu-jitsu, boxing, kickboxing, grappling, judo, Muay Thai, and freestyle and Greco-Roman wrestling. Mixed martial arts matches promoted by the Ultimate Fighting Championship® (“UFC”), the world’s largest professional mixed martial arts promoter, regularly fill the nation’s—and indeed, the world’s—largest arenas. The viewership of mixed martial arts on network and pay-per-view (“PPV”) television now far outstrips that of professional boxing and wrestling. Professional mixed martial arts made its debut on prime time ny-1059083 Case 1:11-cv-08215-KMW Document 34 Filed 09/24/12 Page 2 of 178 network television in 2008, with CBS’s live broadcast of fight cards by mixed martial arts promotion EliteXC.
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