A Collection Of Literary Gems From The UFC's Lawsuit Against New York

Zuffa, the UFC's parent company, has sued New York officials in an attempt to overturn the state's idiotic ban on MMA, a prohibition that drives the sport underground and exists chiefly because of the efforts of one misguided moralist. Several prominent fighters, including light heavyweight champ Jon Jones and female MMA starlet have teamed up with Zuffa for the legal battle, which is being cast as a First Amendment issue and a fight over freedom of expression. Over liberty and so forth. Cool. Let's not get carried away. The UFC is acting in its own self-interest. Which is fine. But the company could also open up the state to other MMA promoters. Which is fine, too. We'll be following the case as it develops.

For now, let's commend the UFC's lawyers for filing a remarkable complaint. The 123-page document ranges over thousands of years of history, Taoism, agrarian harvest rituals, David Mamet, and so much more. At points, it made me weep (almost). What we have here, folks, is literature, and I intend to treat it as such. Behold the following passages.

UFC lawyers on expression:


Professional MMA athletes exhibit great prowess; their abilities are the product of years of rigorous training and discipline. During a live performance, these professionals express themselves with their bodies and their abilities, conveying messages of, among other things, skill, courage, self-discipline, self-confidence, the value of intense training, humility, strategic thinking, and respect for one's opponent. The objective is to win, not harm.

UFC lawyers on brotherhood:

MMA fighters frequently show great respect for one another during matches. Even long-time rivals pitted against each other will touch gloves before a fight, and they will embrace and thank each other afterward. Fighters often speak of the brotherhood that exists among them. It is unfathomable that in a world drenched in violence—from first-person shooter video games, to violent movies to violent lyrics in pop music, to graphic network news—the New York legislature singled out live professional MMA as the one thing is believes sends an impermissible message.

UFC lawyers on philosophy:


MMA is derived from traditional martial arts. These martial arts have been inextricably intertwined with expressive culture for at least the past five thousand years. The term 'martial art' is the common English translation of the Japanese budo (bu=war, martial + do=path, way). The concept of 'path' or 'way' is related to the Chinese notion of the Tao/Dao—the core image of Taoism, a philosophy that advocates a lifestyle in harmony with the natural order. As developed in Japan and transmitted to the West during the late nineteenth century, the martial arts that make up MMA have been understood to allude not only to technical combat skills, but to moral, spiritual, and social codes, as well.

UFC lawyers on horticulture:

Various expressive genres have utilized martial arts to transmit the core values of society, mark moments of siginifcance to the community, and commune with higher powers. For example, in some indigenous cultures, horticulturalists wrestle in the fields before or after harvest. Victory in these matches is incidental. The matches serve a prayers to the powers that invigorate the soil.

UFC lawyers on Bruce Lee:

On the expressive message of martial arts, Bruce Lee was unequivocal, stating: "But if you don't have [martial art] styles, how can [I] express myself totally and completely? ... To me ... ultimately, martial art means honestly expressing yourself...." Lee's moves bear noticeable resemblance to present-day MMA.

UFC lawyers on risk:

Although MMA is undoubtedly a combat sport and not without some risk, these sorts of risks are common to many sports. It is risk and challenge that bring people to live sporting events as spectators and that drive athletes to train and excel to perform in them.

UFC lawyers on boxing:

[I]n a typical boxing match, which many people (incorrectly) believe to be safer than MMA, boxers generally land several hundred punches to an opponent's head and body. MMA competitors land only a fraction of that amount. That is because much of the sport of MMA occurs on the ground, with the fighters grappling rather than striking. The number of strikes landed is a critical metric in evaluating comparative safety. It is precisely the mixed nature of MMA that renders it safer.

UFC lawyers on tightrope walking:

Even daredevil athletic displays are allowed by the State of New York. This past September, Governor Andrew Cuomo signed into law a bill allowing tightrope walker Nik Wallenda to trek 1,800 feet over Niagara Falls while balancing on a two-inch diameter steel cable. A long list of local politicians, eager to bring tourism and revenue into the economically depressed Niagara region, supported the bill.

UFC lawyers on hockey:

In ice hockey, players are hit from behind, have their heads and bodies slammed into the boards, are hit by frozen-hard pucks, checked with wooden sticks, slashed by ice skate blades, and, notably, engage in bare knuckle brawls on the ice.

UFC lawyers on inspiration:

The sport is popular with fighters and fans both because it signifies (among other things) what remarkable skill and training can accomplish, that such skill and training can easily defeat brawn and brutality, that respect for one's opponent is not inconsistent with combat sports, and that courage in the face of a challenge is a trait to be emulated. For some, MMA may be about violence, but for most, MMA carries a message of discipline, challenge, and inspiration.

UFC lawyers on accomplishment:

Fighters compete in professional MMA matches for a variety of reasons, including, naturally, the desire for fame and fortune. But many fighters also fight because live fighting is the ultimate showcase of what they have accomplished in training. Many describe their public fights as the "culmination" of what they have strived for, the chance to demonstrate to those watching their hard-won skill and technique, their discipline, their courage, and their determination to win.

UFC lawyers on movement:

The moves, strikes, holds, and maneuvers used by MMA fighters are neither random nor ad-hoc. They are practiced, honed, and carefully planned and executed. Mixed martial arts, like all martial arts, is an art indeed.

UFC lawyers on dance:

MMA is an organic process in which fighters are constantly testing new moves and responses to new moves, seeing what the human body can accomplish. In this way, MMA bears a great resemblance to dance.

UFC lawyers on respect:

[I]t is common for fighters to develop close friendships with and mutual respect for their competitors. Even when opponents do not know one another, they commonly signal their respect for one another by touching gloves before a match and embracing and exchanging congratulations afterward. Accomplished martial artists of various disciplines explain that in a match, one fights with oneself. An opponent is a person who allows this opportunity to test and express oneself. Thus, an opponent is to be respected for affording this opportunity.

UFC lawyers on performing:

MMA fighters participate in live events for the same reason that an actor plays a crowded hall, a figure skater skates in front of thousands of live fans, a ballerina dances at Lincoln Center, and a band plays in a packed auditorium....

UFC lawyers on storytelling:

The fighters are athletes and performers both. Live professional MMA matches provide fighters with myriad expressive outlets, allowing fighters to build relationships with their fans and tell the world their story.

UFC lawyers on walkouts:

Fighters have used this time to entertain the audience, show who they are, what they believe in, and send messages as they feel the need. ... Strikeforce fighter Muhammed "King Mo" Lawal enters his fights with many female backup dancers who throw petals at his feet.

UFC lawyers on purity:

Fans are drawn to the purity and authenticity of MMA. In a world rife with fake sports (professional wrestling), fake interactive adventures (video games), and even fake reality (reality television), MMA stands out as distinctly "real." The message conveyed by MMA athletes is a pure one: they are using their hard-practices skill, strategy, mental conditioning, and determination to achieve victory.

UFC lawyers on Jon Jones:

He wants to fight in Madison Square Garden like his role model Muhammad Ali, but cannot do so because of the Live Professional MMA Ban.

UFC lawyers on Gina Carano:

Were it not for the Live Professional MMA Ban, Carano would fight professionally in New York.

UFC lawyers on Frankie Edgar:

It is a lifetime dream for Edgar to fight in New York, particularly at Madison Square Garden, which he considers "the most famous" arena in the world. As a New Jersey native, he would love for his friends and family to be able to watch him fight in New York.

It goes on....