Case 1:22-cv-08178-PGG Document 6 Filed 09/26/22 Page 1 of 14

UNITED STATES DISTRICT COURT

Matchroom Boxing Limited; and Civil Action No.:

Plaintiffs,

— against — COMPLAINT

Jake Paul, Jury Trial Demanded

Defendant.
-------------------------------------------------------X

Plaintiffs, Matchroom Boxing Limited (“Matchroom Boxing”) and Edward (Eddie) John

Hearn (together, “Matchroom” or “Plaintiffs”), by their attorneys Salzano, Lampert & Wilson

LLP, allege as follows:

NATURE OF THE ACTION

1. It is axiomatic that a reputation is earned slowly and lost quickly.

2. For over three decades Matchroom has worked tirelessly to build its reputation as

the preeminent boxing promoter in the world. Matchroom unequivocally respects the rules and

guidelines of the boxing profession, acts with integrity and transparency, and treats boxers and

others involved in the boxing profession fairly and with dignity.

3. Defendant Jake Paul (“Paul” or “Defendant”) has earned tens of millions of dollars

as a social media influencer, boxer, and boxing promoter. He is frequently interviewed by the

media and is well-known in the boxing profession and mainstream media. Defendant also

maintains a substantial following on social media, with approximately 20.7 million followers on

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Instagram, 20.4 million subscribers on YouTube, 16.6 million followers on TikTok, 5.7 million

followers on Facebook, and 4.4 million followers on Twitter.1

4. In light of his substantial following, when Defendant speaks, boxing fans, media,

and the boxing profession listen. The spoken and written words of the Defendant are inevitably

spread globally with the potential to harm the reputation of any individual or entity.

5. Although playful banter and even smack talk criticizing rivals is common in the

boxing profession, Defendant’s recent, outlandishly false and baseless accusations against

Matchroom, which are detailed below, crossed far past the line of banter, and clearly constitute

defamation.

6. On or around September 20, 2022, Defendant made outrageously false and baseless

accusations against Matchroom in a video that was posted online and made available free of charge

to anyone across the world.2 Defendant claimed without a shred of evidence to substantiate such

claims that Matchroom paid off boxing judge Glenn Feldman (“Feldman”) to score the recent bout

between Oleksandr Usyk (“Usyk”) and Anthony Joshua (“Joshua”) in Saudi Arabia, and that

Matchroom also paid off Feldman to score a separate bout between Katie Taylor (“Taylor”) and

Amanda Serrano (“Serrano”) in April 2022 that was held at Madison Square Garden in New York

City. Defendant further stated that, because of Matchroom’s bribes, Feldman scored in favor of

Joshua and Taylor (the “Fighters”) respectively. Matchroom was the promoter for both Fighters,

1
The earnings and social media data are sourced from: (1) Daniel Yanofsky, Jake Paul Net Worth, The Sporting
News, July 26, 2022, available at https://www.sportingnews.com/us/boxing/news/jake-paul-net-worth-purse-
history-career-earnings-youtube-boxing/htcxfgjhd7mmshflxcjguvlx; (2) Twitter, Sept. 21, 2022,
https://twitter.com/jakepaul?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eauthor; and (3) Instagram,
Sept. 21, 2022, https://www.instagram.com/jakepaul/?hl=en.
2
A video recording of Defendant’s statements are incorporated herein by reference, and available at:
https://twitter.com/ifltv/status/1572337128515993600?s=46&t=Iv4jr1LmoaHVwYJ4Ke6E8g. And, a transcript of
the most pertinent aspects of Defendant’s statements is attached hereto as Exhibit A.

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with Taylor securing a split decision victory over Serrano and Joshua losing by split decision to

Usyk. Defendant was and remains the promoter of Serrano.

7. Specifically, on or around September 20, 2022, Defendant stated: “clearly this guy

is getting paid money by Matchroom Boxing.” See supra note 2. At the time he made the statement,

Defendant recognized the enormity of his proclamation against Matchroom: “that’s a bold

statement and an accusation that I don’t take lightly, but it’s just so blatantly obvious and they’re

not even trying to hide it.” Id. Defendant went even further in his false and baseless claims against

Matchroom, stating: “you’d think they would try to get a different judge to try and hide the

corruption they are bringing to this sport but it’s just so blatantly obvious.” Id. Defendant likewise

stated that Matchroom has engaged in “a repeated crime.” Id.

8. Thus, not only did Plaintiffs recognize that Defendant’s statements crossed the line

from banter and clearly amount to defamation, Defendant himself, at the time he made the false

and baseless statements, explicitly acknowledged that his accusations were “bold.”

9. Such accusations are obviously deeply offensive as well as damaging to Plaintiffs.

They are also patently false. As Defendant should be aware (given his own activities as a boxing

promoter), the applicable boxing commission, i.e., the Middle Eastern Professional Boxing

Commission for the bout between Usyk and Joshua, and the New York State Athletic Commission

for the bout between Taylor and Serrano – not the promoter of the bouts – is responsible for

choosing the judges. Therefore, by definition, the Plaintiffs could not have appointed Feldman as

Defendant insinuated. Furthermore, it is worth noting that: (i) the majority of media concurred

with Feldman’s scorecard in respect of the Taylor bout and many remarked on the remarkable

achievement of both fighters in what was deemed a closely contested ‘fight of the year’ candidate3;

3
See e.g., https://www.sportingnews.com/us/boxing/news/katie-taylor-vs-amanda-serrano-live-results-
highlights/hat68l72vmsni1aho04bam7v.

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and (ii) Mr. Hearn himself publicly disagreed with Feldman’s scorecard in respect of the Usyk-

Joshua bout, stating that he believed Usyk won the fight.4

10. Defendant’s wild accusations against Matchroom caused a media and social media

frenzy undoubtedly exacerbated by Defendant’s enormous social media following.

11. Within 24 hours of Defendant’s false statements, several news and social media

sites replayed Defendant’s false and accusatory statements, while others wrote about Defendant’s

claims regarding Matchroom.

12. Media characterized Defendant’s statements as “damning accusations” against

Matchroom and “EXTREMELY STRONG ACCUSATIONS” against Matchroom (emphasis in

the original). See infra ¶¶ 40-46.

13. The media blitz has continued up to the filing of this complaint, and is likely to

continue into the foreseeable future. Given Defendant’s far-reaching social media presence, his

statements have reached tens of millions of individuals across the globe.

14. Defendant’s defamatory statements were made with malicious intent and have

caused financial and reputational harm to Plaintiffs, which is precisely what Defendant intended

when he made the outlandish accusations.

15. Following Defendant’s explosive and unfounded statements, Matchroom

representatives contacted Defendant through his agent, and urged Defendant to retract the false

accusations. Defendant refused to comply with Matchroom’s request, thus doubling-down on his

malicious and defamatory statements against Matchroom.

16. Matchroom brings this complaint against Defendant for defamation.

4
See e.g., https://www.boxingscene.com/hearn-i-usyk-winning-115-113-what-he-tenth-round-unbelievable--
168514.

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JURISDICTION AND VENUE

17. This is an action for substantial damages in an amount in excess of the minimum

jurisdictional limits of this Court.

18. This Court has subject matter jurisdiction over this case pursuant to 28 U.S.C. §

1332 (diversity jurisdiction) in that it is a civil action between citizens or subjects of a foreign state

and a citizen of a State and involves an amount in controversy in excess of $75,000 (exclusive of

interest and costs).

19. Defendant is subject to personal jurisdiction pursuant to New York’s long-arm

statute because Defendant transacted business in New York as the co-promoter of the Taylor-

Serrano bout, which was held at Madison Square Garden in Manhattan and is one of the two bouts

in which Defendant has baselessly accused Matchroom of engaging in criminal behavior. N.Y.

C.P.L.R. § 302(a)(1) (“Section 302”) confers personal jurisdiction for a court over a non-

domiciliary defendant “[a]s to a cause arising from any of the acts enumerated in this section . . .

who in person or through an agent . . . transacts any business within the state or contracts anywhere

to supply goods or services in the state . . . .” N.Y. C.P.L.R. § 302(a)(1).

20. Venue is proper in this District pursuant 28 U.S.C. § 1391, as Defendant’s

defamatory statements reached this District, Defendant has minimum contacts with this District

due to, for example, his co-promotion of the Taylor-Serrano fight, which was held at Madison

Square Garden in Manhattan and is one of the two bouts in which Defendant has baselessly accused

Matchroom of engaging in criminal behavior, and Matchroom Boxing’s U.S. subsidiary is located

within this District. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 474–75 (1985).

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THE PARTIES

21. Matchroom Boxing is a private limited company organized and existing under the

laws of the United Kingdom, with its principal place of business in the United Kingdom.

22. Eddie Hearn is an individual, who resides in Essex, England, and is the chairman

of the Matchroom group of companies, a boxing promoter, sports executive, media personality,

and award-winning author.5

23. Defendant is an individual, and upon information and belief, resides in Dorado

Beach, Puerto Rico.

24. Defendant is a social media influencer, boxer, and boxing promoter, and recently

launched a sports-betting company called Betr.6

25. Defendant also co-founded the boxing promotional company, Most Valuable

Promotions.

26. According to a news report, Defendant maintains over 70 million followers on

social media and is one of the most searched public figures on Google.7

FACTUAL ALLEGATIONS

A. Matchroom’s Excellent Reputation in the Boxing Profession

27. Matchroom is firmly established as the foremost fight promoter in the world.

28. With over three decades of vast experience in the boxing industry, the company has

taken boxing onto another level with a series of ground-breaking promotions that have broken all

records for ticket sales and viewership.

5
See https://www.goodreads.com/book/show/59732054-relentless.
6
See Jordan Kirkland, Jake Paul Launches Miami-Based Sports Betting Company, Betr, The Capitolist, Aug. 8,
2022, available at https://thecapitolist.com/jake-paul-launches-miami-based-sports-betting-company-betr/.
7
See supra note 1.

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29. Matchroom’s current stable of fighters includes well-known athletes such as

Joshua, Taylor, Saúl “Canelo” Alvarez, Julio Cesar Martinez, Jesse Rodriguez, Jessica McCaskill,

and many more.

30. To earn and maintain its fantastic reputation, Matchroom unequivocally respects

the rules and guidelines of the boxing profession, acts with transparency and integrity, maintains

robust and unwavering anti-bribery and corruption policies, and has long treated boxers fairly and

with dignity.

B. Defendant’s Defamatory Statements Against Matchroom

31. On or about September 20, 2022, Defendant made outrageously false and baseless

accusations against Matchroom.

32. Defendant claimed that Matchroom paid off scoring judge Feldman to score the

bout between Usyk and Joshua (which was held in Saudi Arabia), as well as an earlier bout between

Taylor and Serrano (which was held in Madison Square Garden in Manhattan), in favor of Joshua

and Taylor respectively, due to those fighters’ professional connections to Matchroom.

33. Referring to Feldman, Defendant stated: “clearly this guy is getting paid money by

Matchroom Boxing.” See supra note 2.

34. At the time he made the statement, Defendant recognized the enormity of his

proclamation against Matchroom: “that’s a bold statement and an accusation that I don’t take

lightly, but it’s just so blatantly obvious and they’re not even trying to hide it.” Id.

35. Defendant went even further in his false claims against Matchroom, stating: “you’d

think they would try to get a different judge to try and hide the corruption they are bringing to this

sport but it’s just so blatantly obvious.” Id.

36. Defendant likewise stated that Matchroom has engaged in “a repeated crime.” Id.

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37. All of Defendant’s foregoing statements regarding Matchroom are false.

38. Matchroom did not provide authorization to Defendant to make any of the

aforementioned statements.

39. On information and belief, the foregoing statements of Defendant were made and

published (i) with actual malice and knowledge of their falsity, and (ii) with the design and intent

to harm Matchroom in its profession.

C. Defendant’s Defamatory Statements Reached a Broad Audience

40. In less than twenty-four hours, Defendant’s defamatory statements reached a very

broad audience. In large part this is due to the fact that Defendant enjoys a substantial social media

following—with over 70 million followers—and due to the fact that Defendant is one of the most

searched public figures on Google. See supra note 1 and accompanying text.

41. For example, iFL TV, a well-known boxing media site, when publishing the

interview, referred to Defendant’s statements in a Twitter post as “EXTREMELY STRONG

ACCUSATIONS” against Matchroom.8

42. An article on Boxing Social, another well-known boxing media site, boasted in a

headline that “Jake Paul Makes Extremely Serious ‘Corruption’ Allegation Against Matchroom.”9

43. The Boxing Social article noted that Defendant, as a promoter, was on the losing

end of the Taylor-Serrano fight. See supra note 9. The article further explained that although

scoring disagreements are common in boxing, “rarely do they result in such a stark and targeted

accusation.” Id.

8
See https://twitter.com/ifltv/status/1572337128515993600?s=46&t=Iv4jr1LmoaHVwYJ4Ke6E8g (emphasis in the
original).
9
Kerr Ferguson, Jake Paul Makes Extremely Serious “Corruption” Allegation Against Matchroom, Boxing Social,
Sept. 20, 2022, available at https://boxing-social.com/news/jake-paul-allegation-against-matchroom/.

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44. A separate article, published on the respected website, Boxing Scene, was titled

“Jake Paul Alleges Judge Glenn Feldman ‘Clearly . . . Getting Paid Money by Matchroom

Boxing.’”10

45. The Boxing Scene article referred to Defendant’s statements as “damning

allegations.” See supra note 10. The article further pondered why Defendant, rather than note his

disagreement with the scoring, claimed “corruption between Feldman and Matchroom.” Id.

46. The aforementioned articles represent just a small subset of publications that

highlighted Defendant’s outlandishly false and defamatory statements regarding Matchroom.11

D. Defendant Knew, or Should Have Known, That His Statements Were False

47. Defendant knew, or should have known, that his accusations were false at the time

that he made them.

48. Not only is Defendant a boxer, he is also a boxing promoter and a co-founder of a

boxing promotional company. As such, Defendant is—or at the very least should be—intimately

familiar with how judges are selected for fights.

49. As Defendant should be aware—the applicable boxing commission, i.e., the Middle

Eastern Professional Boxing Commission for the bout between Usyk and Joshua, and the New

10
Jake Donovan, Jake Paul Alleges Judge Glenn Feldman “Clearly . . . Getting Paid Money by Matchroom
Boxing,” Boxing Scene, Sept. 21, 2022, available at https://www.boxingscene.com/jake-paul-alleges-judge-glenn-
feldman-clearly-getting-paid-money-by-matchroom-boxing--169206.
11
Some additional news reports include: Jake Paul Accuses Boxing Judge of Being Paid by Matchroom Boxing,
Fight Sports, Sept. 21, 2022, available at https://www.fightsports.tv/jake-paul-accuses-boxing-judge-of-being-paid-
by-matchroom-boxing/; Joshua Ben Joseph, “It’s Like a Repeated Crime Here”: Jake Paul Makes Serious
Accusations Against Anthony Joshua’s Promoter Eddie Hearn, Essentially Sports, Sept. 21, 2022, available at
https://www.essentiallysports.com/boxing-news-its-like-a-repeated-crime-here-jake-paul-makes-serious-accusation-
against-anthony-joshuas-promoter-eddie-hearn/; and Jake Paul Acusa al Juez Feldman de Recibir Dinero de
Matchroom Boxing, NotFight, Sept. 21, 2022, available at https://notifight.com/jake-paul-acusa-al-juez-feldman-de-
recibir-dinero-de-matchroom-boxing/.

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York State Athletic Commission for the bout between Taylor and Serrano—not the promoter of

the bouts—is responsible for choosing the judges.

50. Thus, it is factually impossible for Matchroom to have engaged in what Defendant

called “corruption” by bringing Feldman in as a judge. It simply was not Matchroom’s decision to

do so, and Defendant knew, or should have known, that.

51. Furthermore, there is absolutely no evidence that Matchroom has engaged in any

wrongful conduct, let alone bribing a judge in both of the aforementioned bouts.

52. Defendant’s motivations for his false, baseless, and accusatory statements are not

difficult to discern. Defendant was the promoter for Serrano in the Taylor-Serrano fight, and

Matchroom was the promoter for Taylor. Taylor won the fight in what Sports Illustrated later

called “the fight of the year—full stop.” 12 Sports Illustrated, a preeminent sports media

publication, detailed how the fight between the women was “a classic,” and further wrote that

Taylor’s win “cemented her place” as one of the most accomplished fighters in women’s boxing,

and arguably “enhanced her case to be called the greatest women’s boxer of all time.” See supra

note 12. Nothing in the article even remotely called into question the scoring of the fight, let alone

mentioned any potential wrongful conduct on the part of Matchroom. Id.

E. Matchroom Has Suffered Damages Due to Defendant’s Defamatory Statements

53. Matchroom has suffered, and will continue to suffer, significant financial and

reputational damages due to Defendant’s defamatory statements.

54. The world of professional boxing is closely knit, with only a handful of individuals

and companies vying for the right to work with premier boxers. Matchroom’s strengths as trusted

12
Chris Mannix, Katie Taylor vs. Amanda Serrano Was the Fight of the Year—Full Stop, Sports Illustrated, May 2,
2022, available at https://www.si.com/boxing/2022/05/02/katie-taylor-amanda-serrano-madison-square-garden-
fight.

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advisor, promoter, matchmaker, and ultimately presenter of fair, compelling and competitive

televised contests have been core components of the company’s undisputed integrity in the

business. Defendant’s defamatory statements are therefore particularly damaging to Matchroom

and go to the very core of its business.

55. The negative impact of Defendant’s defamatory statements about Matchroom have

been magnified because once Defendant initiated his false and scandalous allegations, they have

been repeated and paraphrased by reporters throughout the United States and internationally.

56. These additional publications and paraphrasing of Defendant’s defamatory and

libelous statements were foreseeable, and, on information and belief, Defendant anticipated and

desired such additional publications in order to cause even more injury to Matchroom’s business

and reputation.

COUNT ONE

(Defamation)

57. Matchroom repeats and realleges each and every allegation in paragraphs 1 through

56 as if fully and completely set forth herein.

58. Defendant made his false and defamatory statements deliberately and maliciously

with the intent to intimidate, discredit, and defame Matchroom.

59. Defendant has made statements of fact against Matchroom that are false.

60. At the time Defendant made his statements, Defendant knew, or should have

known, that the statements were false.

61. Defendant’s statements were made to reporters, newspapers, and other public

outlets, among other places and persons. The statements were not privileged.

62. Defendant’s statements were published to a broad audience.

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63. Defendant deliberately made the statements knowing they would be disseminated

to a broad audience and would harm Matchroom’s reputation and good standing. Defendant acted

with spite and malice when making the defamatory statements. As intended by Defendant,

Defendant’s defamatory statements were, in fact, widely published and disseminated around the

world, including in the Southern District of New York.

64. Given the absence of any evidence to substantiate Defendant’s statements,

Defendant issued his statements with actual knowledge that such statements were false and in

reckless disregard for their falsity. In either case, Defendant issued these statements intending to

harm Plaintiffs.

65. Defendant’s statements harm Plaintiffs’ reputation in the public, impute the

commission of a crime, and/or call into question Plaintiffs’ fitness to perform its work in its trade

and profession.

66. Defendant’s false statements constitute slander, as he spoke false statements about

Plaintiffs in a video that was, upon information and belief, recorded by a third party, and knew that

the statements were going to be transmitted in writing, and widely disseminated on the Internet in

video and/or in print. Defendant intended his false statements to be published by newspaper and

other media outlets internationally, and they were, in fact, published globally, including within the

Southern District of New York.

67. Defendant’s false statements constitute slander per se, including that they accused

Matchroom of a crime of significant proportion in the sport of professional boxing, and including

that they exposed Matchroom to public contempt, ridicule, aversion, and disgrace, and induced an

evil opinion of Matchroom in the minds of right-thinking persons.

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68. Defendant’s false statements constitute libel, as he knew that they were going to be

transmitted in writing, and widely disseminated on the Internet and in print. Defendant intended

his false statements to be published by newspaper and other media outlets internationally, and they

were, in fact, published globally, including within the Southern District of New York.

69. Defendant’s false statements constitute libel per se, including that they accused

Matchroom of a crime of significant proportion in the sport of professional boxing, and have thus,

exposed Matchroom to public contempt, ridicule, aversion, and disgrace, and induced an evil

opinion of Matchroom in the minds of right-thinking persons.

70. Defendant’s false statements also constitute libel per se, inasmuch, among other

reasons, as they tended to injure Matchroom in its professional capacity as a premier promoter of

boxing events, and inasmuch as they intended to destroy Matchroom’s credibility and reputation

among members of the boxing community and profession.

71. Because Defendant’s conduct was undertaken in bad faith and with fraud, malice,

and oppression, Matchroom is entitled to punitive damages.

72. Defendant knowingly made false statements to third parties with actual malice and

knowledge of their falsity, and which tended to injure Matchroom in its profession constituting

defamation per se.

73. As a consequence of Defendant’s defamatory statements, Matchroom is entitled to

substantial and significant damages in an amount to be determined at trial.

74. Defendant’s false statements have caused, and continue to cause, Matchroom

economic damage and reputational harm, and other direct and consequential damages and losses.

75. Matchroom is also entitled to recover punitive damages from Defendant in that

Defendant made his defamatory statements: (i) with knowledge of its falsity and/or with wanton

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