September 8, 2014
Late last week, the last round of briefing in its motions for summary judgment have been filed by the parties in the Zuffa lawsuit in New York. Both sides made its final arguments to the Court in hopes of prevailing on summary judgment. The parties filed its reply briefs which address arguments made by the opposing side which rebut the initial summary judgment motions made by the parties.
To refresh your memory, New York is seeking to dismiss Zuffa’s lawsuit in total. It has already dismissed 6 of the 7 claims made by Zuffa in the lawsuit to legalize pro MMA in the state. Zuffa is attempting to strike down the law with its motion.
Zuffa’s Reply Brief
Zuffa reiterates some key points in its final briefing before the Court’s review. The emphasis is that the statute banning pro MMA (sec. 8905-a) is unconstitutionally vague (which is the remaining legal claim).
First, it notes that there are two independent reasons why a statute is vague: 1) lack of notice; and 2) the statute’s arbitrary or discriminatory enforcement. Zuffa states that the first prong is sufficient for the court to grant summary judgment in favor of Zuffa. In explaining its position, Zuffa states the standard that “a person of ordinary intelligence” would have reasonable opportunity to know what is prohibited. Here, it argues that no one could know what is prohibited based on this statute.
The overarching theme for Zuffa is that the statute is so confusing that even state officials are not able to interpret it. It hammers home this point through the example of the state’s Attorney General agreeing at oral argument that an exempt organization can sanction a pro MMA event. Thus, how can the law be enforced.
In addition, it refutes an argument made by New York in its opposition brief that exempt organizations can sanction to only “single discipline” “traditional” “long recognized” martial arts. Zuffa points out in its legal argument that New York misinterprets and/or misreads the statute in its favor. Essentially, New York attempts to cite legislative history when one need only look to the plain meaning of the statute. Nowhere in the statute does it preclude pro MMA from being sanctioned by an exempt organization. Yet, Zuffa argues that New York tries to read into the statute. Zuffa also argues that the state’s enforcement has been arbitrary or discriminatory. In this argument, it states that after discovery in the case, it became clear that state officials lacked clear guidance in enforcing the statute. Here, Zuffa points out inconsistencies obtained through the discovery process (i.e., written interrogatories and/or depositions).
New York Reply Brief
New York argues for the dismissal of Zuffa’s case and in so doing it reiterates its strategy that the plaintiffs lack legal standing to bring this claim in federal court. It also argued that due to the fact that the statute is one of state law, a state court should render the opinion here. In supporting its lack of legal standing argument, it suggests that Zuffa had a mere “oral understanding” with an exempt organization (here the World Kickboxing Association) when Zuffa argued that it had an agreement with the WKA to sanction an event in the state. If it is found that there was an agreement, it would satisfy the legal standards of standing as there would be a recognizable injury (i.e., New York is preventing Zuffa from conducting an event through the WKA).
However, New York points out there was no written contract, details or anything else that has surfaced as evidence. New York also notes that the declarations in support do not indicate when the agreement between Zuffa and WKA took place. It also intimates that the claim that Zuffa and WKA had an agreement to sanction an event did not happen until after the filing of this lawsuit. It also argues that a state statute should be interpreted by a state court and that Federal jurisdiction should abstain from ruling until the state has interpreted the law. Here, it appears that a state court has yet to generate an opinion on the statute. In addition to its briefing, there is also the motion to strike brought by New York regarding some of the evidence cited by Zuffa in its briefing. If the court were to grant New York’s motion, a huge chunk of Zuffa’s argument would go away.
It does not appear that the court has determined whether there will be an oral argument in this case. The court, in its discretion, may review the pleadings and decide at that point whether an oral argument will help it make its decision. Once again, Zuffa provides solid legal arguments. The question is whether the arguments would satisfy the Summary Judgment standard which is whether there are no genuine issues of material fact, summary judgment is proper. As for New York, it is giving the court “an out” with its arguments (lack standing, state court proper forum). MMA Payout will continue to keep you posted.
September 8, 2014
The overnight audience numbers from Friday’s UFC and Bellator shows have come in and are in line with the initial ratings we brought to you on Saturday. The UFC drew 911,000 viewers for its main card while Bellator MMA drew 667,000 viewers.
In addition, the 3 hour UFC Prelims preceding the UFC Fight Night 50 main card drew 485,000 viewers.
According to a Nielsen source both main cards went head to head from 10-10:45pm (7-7:45pm on west coast) with the UFC main card on FS1 edging out Bellator on SpikeTV 834,000 to 781,000. Jason Floyd of The MMA Report tweeted the total number of viewers watching UFC or Bellator were 1.6 million viewers.
For those wondering, the WWE’s taped programming of Smackdown scored 2.7 million viewers on the SyFy channel. If you are Bellator, you can see the ratings as a positive from the perspective that when it went head to head against the UFC, it was not too far off the UFC viewership. Still, in the end, the UFC prevailed on FS1. We will see if Bellator will be able to keep up the momentum in viewers this week. As for UFC Fight Night 50, the ratings are up from the 689,000 viewers of UFC Fight Night 49.
September 1, 2014
Welcome to another edition of Payout Perspective This time we take a look at UFC 177 which took place at the Sleep Train Arena in Sacramento, California where T.J. Dillashaw defeated his bantamweight title against Joe Soto.
Dillashaw KO’s Soto in 5th round
It was not Renan Barao, but T.J. Dillashaw was able to end the fight in the 5th round again as he disposed of a game Joe Soto. Dillashaw described himself as a “company man” and there was no issue about whether he’d take the new opponent on a day’s notice. For Soto, it was a solid effort in his debut fight in the UFC. Both fighters are likely in the good graces of the UFC. Who is not on the UFC’s good side? Renan Barao for not making weight. The former champ, who just this past May was praised by Dana White, is now on the outs with the organization for not making the 135 pound limit. White’s distaste toward Barao may be fueled by the already anticipated lack of buzz in this event.
Attendance and gate
Although the initial thought was that this event would pull a small attendance and gate, it actually exceeded the amount of fans that saw Dillashaw-Barao this past Memorial Day weekend. The secondary market reflected the fact that demand was low. But, the amount off walkups and discounted tickets helped with the attendance and gate figure.
As reported, bonuses of $50K each went to Dillashaw, Yancy Medeiros, Carlos Diego Fierra and Ramsey Nijem with the last two awarded Fight of the Night. Despite a slick first round sub on the first fight of the UFC Prelims on FS1, Chris Wade was shut out from reported bonuses.
Sponsors in the Octagon tonight were Las Vegas.com, video game Assassin’s Creed Unity, Fram, Musclepharm, Harley Davidson, Toyo Tires, Corn Nuts, Alienware, MetroPCS, Xyience and Bud Light had the center.
MetroPCS and Harley Davidson were the most notable sponsors with activation surrounding the event. MetroPCS did its usual social media promotion including its “Tale of the Tweet” app. Harley Davidson launched the Hometown Throwdown III promotion in which fans could win the opportunity to have the UFC come to their town as well as throw a tailgate party before the event. The fighters that won their fights on the main card of 177 received a Harley Davidson.
Promotion of T.J. DIllashaw
While many have criticized the card, the one thing that may be overlooked is the great job the UFC did in building the T.J. Dillashaw brand. It’s understandable for the cynical UFC fan to say if the UFC was doing such a great job, this would not be “overlooked.” But, regardless of the fights on the card, the UFC’s shoulder programming has done a great job in building Dillashaw.
In watching the Countdown show and the Embedded vlogs the UFC has introduced people to Dillashaw and you get to see someone deal with all of the responsibilities of being champion. The one plus from my perspective is that Urijah Faber was not used as the bridge to introduce Dillashaw. This may seem absurd, but since Faber is a name and trains with Dillashaw it would make sense for Faber to be the one to introduce him.
Can Dillashaw be a draw? As it currently stands, fans are underwhelmed with the lighter weight divisions. Despite being one of the best in the business, Demetrious Johnson has not sparked the interests of the UFC universe. Jose Aldo has not been healthy enough for anyone to remember how vicious he once was and despite banking blue chip sponsors; Anthony Pettis has not been in the Octagon in ages. If Dillashaw can string some wins together and defeat a guy like Dominick Cruz, I could envision the UFC marketing him much more.
Odds and ends
While I just praised the shoulder programming in the previous section, one of the scenes in the Embedded vlogs was Team Alpha Male doing a ticket giveaway for UFC 177 which foreshadowed the issues with selling this event.
If you were watching the Embedded episodes, Dillashaw did a lot of post-workout work in a hyperbaric chamber and dreamed of having one in his home. I’m sure Dillashaw got his Hyperbaric chamber in his home after this event.
Barao and Cejudo were not paid per Heidi Fang’s tweet and Jorgenson and Anthony Birchak (who was scheduled to face Joe Soto) were given show and win purses despite not fighting per MMA Junkie. Tough time for Birchak who found his home robbed after coming back from Sacramento.
Bethe Corriea’s quest to run through the Horsewomen continues. Really, if the four ladies are going to go through with this gimmick, someone else has to be good in the group aside from Flair. The good news for Corriea, this “Horsewomen” thing has Rousey wanting to fight her. So, yes, pro wrestling is seeping into your pure MMA sport.
Bellator decided to release Soto’s fight against Joe Warren prior to Saturday night.
— Bellator MMA (@BellatorMMA) August 30, 2014
Just a thought, but as a way to entice or say thank you to those that ordered UFC 177, it could offer them a month’s free use of UFC Fight Pass. I understand that it tacitly admits that the card was not PPV-worthy but if you were to offer something like that, it would build a lot of good will with a loyal fan base. If they have Fight Pass, they tack an extra month for free and if you don’t it gives them a chance to try it for free. I know, probably a lot of administrative headaches with deciphering who ordered the PPV, but it still seems like a good PR move.
Expect a low number for the prelims on FS1. There was one fight in the first hour and lots of filler due to a first round sub. Also, with Henry Cejudo pulling out of his fight with Scotty Jorgensen, there were only three fights set for the two hour time block.
With the first full weekend of college football coupled with the multiple problems with the card, it was the perfect storm for folks to actually “boycott” this card.
Earlier in the week, Dana White landed on a list by GQ naming him one of the sleaziest people in sports. Let’s be honest, any combat sports promoter could be found on this list.
It was likely that if UFC 176 was not cancelled, this event would not have gone forward. But, the UFC could not take the PR hit of cancelling two events in a row. Most importantly, the UFC does not want to confirm what most fans and pundits know; there are too many events. Also, at such a late time for Barao pulling out, it was too late to pull out of the PPV and/or cancel the event. This buy rate will rival that of UFC 174 and maybe even do worse. As an interesting and random note, the first UFC did slightly over 86,000 PPV buys. It would not be surprising that the actual buy rate would rival this number. My take is that we’ll never receive an official number for this event although a range will be given around 90-110K PPV buys.
August 29, 2014
MMA Junkie reports that Renan Barao is out of tomorrow’s UFC 177 main event against T.J. Dillashaw. Barao passed out while attempting to cut weight for Friday’s weigh-ins. As a result, former Bellator champ and newcomer Joe Soto gets the shot tomorrow night.
Soto was set to take on Anthony Birchak on the prelim card. Now, he gets the title shot on Saturday. The sudden change is another hit to a card that has been harshly criticized for the lack of star power and interesting fights for a PPV.
Even before the news of Barao needing to be replaced, this card was a hard sell. Realistically, I’m not sure how much the loss of Barao cost PPV buys unless people wanted to see the rematch. Now, we may assume less people are likely to pay for a Soto-Dillashaw main event. The UFC is not going to cancel the card and its not feasible to convert the card to an FS1 show. So, the UFC will have to rely on its hardcore base for buys. While we thought that UFC 174 was the low-water mark for UFC PPVs, it looks like 177 will be lower.
August 24, 2014
Late last week Zuffa and the State of New York have filed its opposition to each party’s motions for summary judgment. The responsive briefing is the continued litigation in the UFC’s quest to legalize professional MMA in the state.
As you may recall, both parties filed Motions for Summary Judgment. New York filed a Motion for Summary Judgment in hopes of dismissing the remaining claim by Zuffa that the New York law that bans professional MMA is unconstitutionally vague. Zuffa’s Motion for Summary Judgment would essentially strike down the law and preclude New York from its enforcement.
In its opposition to New York’s Motion for Summary Judgment it claims that it has standing to raise its challenge to the New York statute. The argument is in direct rebuttal to New York’s assertion in its moving papers that Zuffa had no standing to bring the lawsuit in the first place since it could not claim injury. Zuffa contends that it does have standing since it was the “object” of the state regulation. Here, Zuffa argues that it was a direct object of the law as it is prohibiting professional MMA in the state.
In addition, it rebuts New York’s contention that there was no injury (and thus no standing). The first was the claim that Zuffa had no plans to hold an event in New York and thus there was no injury. The second contention was that Zuffa had no agreement with an Exempt Organization in the statute (which would allow for it to hold an event in the state). However, Zuffa argues that it “has taken all steps – short of violating the criminal law – to hold a professional MMA event in New York and it need not put itself in legal jeopardy to establish standing.” In fact, in its brief, it indicates it has secured a date at Madison Square Garden for 2015. It also cites that the UFC had discussions with the WKA (“World Kickboxing Association”), an Exempt Organization under the New York law, about working together to hold a UFC event. Zuffa contends that there was a “meeting of the minds” about putting together professional matches in New York.
The opposition papers from Zuffa also argue that the statute in question is vague as to whether it is enforceable on Indian reservations in New York. Specifically, Zuffa argues in its pleadings that “it is interested in promoting events on Indian reservations in New York – particularly if it is unable to do so elsewhere in the state.”
New York responds to this assertion about its enforcement of a state statute on an Indian reservation (which as many know, Indian reservations are governed by federal law). New York argued that it has dominion over “offenses on Indian reservations within the State of New York to the same extent that it has over offenses commented elsewhere in the State.”
In addition, the papers also argue over the vagueness of the statute as it pertains to amateur MMA and the New York liquor statute which allows licenses at events.
Notably, New York is seeking to strike some of the evidence which Zuffa attached to its initial Motion for Summary Judgment stating that it is inadmissible for a variety of evidentiary reasons (e.g., lack of authentication, hearsay, irrelevance, opinion, etc.). The court will have to determine New York’s motion to strike prior to determining how to rule on Zuffa’s motion. Some of the evidence New York would like to have stricken from consideration is the issue with the differing interpretations of the law banning professional MMA in the state by multiple government officials.
The legal argument continues. Zuffa appears to have the clearer arguments in the opposition briefing. However, New York is seeking to strike the evidence which appears to be the most damaging – the multiple interpretations of enforcement of the law. This would undercut the argument that the statute is unconstitutionally vague since a portion of the legal argument is that the multiple interpretations of the law by the same officials that are to enforce it is evidence that the law is vague. If that evidence is wiped from the record, there’s less for the court to consider. We will see how each side responds to the opposition briefing. MMA Payout will keep you posted.
August 19, 2014
Bellator has released Eddie Alvarez from his contract with the organization per a company Media Alert. The media advisory also includes a statement from Alvarez.
Via Bellator media advisory:
Bellator President Scott Coker has released a statement regarding Eddie Alvarez:
“We’ve granted Eddie his unconditional release. Eddie is free to explore the free agent market, we hold no matching rights, and we wish him the best in the future. We sat down with Eddie and his team a few times, and it became pretty clear early on that he just wasn’t interested in fighting for Bellator in the future. We want guys in this organization that want to be here, and after the history Eddie and the former regime had here at Bellator, we decided to move on. We wish Eddie the absolute best of luck with whatever is next for him. It’s a new chapter for everyone involved.”
Eddie Alvarez has also released a statement:
“This was a long process but it’s a decision that everyone seems happy with. I think it’s important to say that I am genuinely thankful for my time at Bellator. I know that sounds a little crazy given everything I went through, but I’ve fought there since 2009, and have been involved in some really amazing fights. The staff there always treated me great, and I’m going to miss seeing a lot of those familiar faces around for sure. Myself and my team had some really good discussions with Scott, but in my heart I knew I was ready to move on and start the next chapter in my career.”
This move is probably not surprising to most following the situation since it was clear Alvarez wanted out and Coker likely wanted a clean break from the old regime. Releasing Alvarez under “amicable” terms lets Bellator move on without having to answer any more questions about the Alvarez situation and it allows Alvarez to move on with his career. We’ll see if his career continues in the UFC or somewhere else.
The one negative for Alvarez here is that he loses leverage with the UFC in negotiating a contract since the UFC is the only place (with the money) where he can land.
UPDATED: 3pm 8/19/14. And just like that Alvarez is in the UFC.
— Dana White (@danawhite) August 19, 2014
August 12, 2014
It was officially announced on FS1’s America’s Pregame that Jon Jones is out of UFC 178 due to a leg injury and his title fight with Daniel Cormier has been postponed until the January 3, 2015 card. In its place, Demetrious Johnson will face Chris Cariaso for the flyweight title.
The news of Jones’ injury stalls the momentum between the Jones-Cormier feud which was amplified by last week’s media day brawl at the MGM Grand. It followed with “hot mics” picking up some unrefined banter between the two which was not to be for public consumption. Yet, it perked everyone’s interest.
Now, it appears that the UFC will replace this hot feud with another title fight featuring Johnson. Of course, the last time Johnson headlined (at UFC 174), it was the lowest PPV output in 10 years.
UFC 178 will still have Connor McGregor on the card so there is still buzz to be made. However, replacing Jones-Cormier with Johnson-Cariaso is a disappointment (and its neither Johnson or Cariaso’s fault). Unfortunately for Johnson, he has yet to translate into a PPV draw and his June showing at UFC 174 reflects the fact that he is not a main eventer. On the bright side, both Jones and Cormier will get time to nurse their respective injuries so that they will be fresh for UFC 182 on Jan. 3rd 2015.
August 8, 2014
MMA Fighting’s Dave Meltzer reports that UFC 175 did between 500,000 – 545,000 PPV buys according to various cable sources. It’s the best showing on PPV since UFC 168.
UFC 175 featured Ronda Rousey defending her title against Alexis Davis and Chris Weidman defending his against Lyoto Machida. Interesting enough, UFC 168 featured Rousey and Weidman although in higher profile matchups: Miesha Tate and Anderson Silva.
The 500-545K PPV buy rate is the highest for 2014 which saw its lowest PPV buy rate in 10 years in UFC 174.
Initial reports of this PPV hitting 500K buys appeared to hold up. It should be considered a positive and reflects the successful duo of Rousey and Weidman. The obvious difference from 168 is that the opponents were higher profile. It’s expected that we should get them again in December with Weidman-Belfort and the possibility of Rousey-Carano.
August 2, 2014
The state of New York and Zuffa filed Motions for Summary Judgment in the ongoing lawsuit which seemingly has no end. The filings, which were filed Thursday of last week, each hope to bring a resolution to the lawsuit filed by Zuffa in November 2011.
As most know that have been following this legal fight, Zuffa and other named plaintiffs filed a lawsuit against the Attorney General of New York in an effort to strike down the existing legislative ban on professional MMA in the state. The Court dismissed most of Zuffa’s claims including a legal claim suggesting it infringed against its First Amendment rights.
The remaining claims before the Court are whether the statute is unconstitutionally vague and the state liquor law which allows for liquor to be sold at events. Both parties have requested the Court to rule in its favor on the remaining claims.
For New York, it is requesting the Court to dismiss the challenges made by Zuffa. If granted, the case would effectively be over pending an appeal to the Circuit Court.
For Zuffa, it is requesting the Court to strike down the law banning professional MMA in the state. This would effectively allow for professional MMA in the state since the law would no longer exist. Of course, we’ll speculate on this later.
The standard for a Court to grant a Summary Judgment has the party filing the motion having to prove that there is “no genuine dispute as to any material fact” and that the person bringing the motion “is entitled to judgment as a matter of law.” Basically, the Court must find that based on the facts presented, there is no reason to hear anything else about the dispute because the facts show there is no dispute. This certainly can be a tough threshold for any party bringing a motion.
New York’s Summary Judgment Motion
New York strategically argues that most of the named Plaintiffs must be dismissed because they have no standing. Essentially, they cannot bring the lawsuit because there is no injury (i.e., damages). In this scenario, if there are no damages, there is no standing to bring the claim. Plaintiffs cannot bring a claim on hypothetical damages, rather the damages must be “actual and imminent.” New York argues that most of the named Plaintiffs including Jon Jones, Gina Carano, Frankie Edgar, Matt Hammill and Brian Stann do not have the requisite standing because each have not suffered an actual injury and thus have no damage claim. The parties had agreed that Jones, et al would not be deposed if they would not provide any evidence of the vagueness allegation. Thus, New York now brings the motion to dismiss them.
It argues that the “only still surviving Exempt Organization,” the World Kickboxing Association (WKA) has only a “tentative” relationship with Zuffa. It also points out that Zuffa and WKA have no formal agreement to run an event or future plans to do so. Thus, Zuffa cannot claim injury.
Arguing that the Plaintiffs have no standing means the Court does not need to rule on the substantive legal issue-whether § 8905-a, the law banning professional MMA (or the New York “Liquor Law” which prohibits licensees who serve alcohol for on-premises consumption) is unconstitutionally vague.
While this may be cynical, arguing the procedural issues rather than the substantive content allows the Court an “out.” Courts would not have to decide on the constitutionality of a law if the procedures to address the actual issue are not met. Rather, Courts could allow the legislative branch the chance to address the law. And, as we know Zuffa has been trying to do this for a while with no success.
If you are looking for a recent case that reflects a Court ruling on procedural grounds rather than substantive, look at the U.S. Supreme Court case which ruled on California’s Proposition 8. In that case, the Supreme Court did not rule on the legal issues as it determined that the private parties that brought the lawsuit had no “standing” to bring the lawsuit because they had no injury.
Here, New York argues that the Plaintiffs have no “standing” to bring the lawsuit because they lack the requisite “injury.”
Zuffa’s Summary Judgment
Zuffa filed its Summary Judgment motion seeking that the Court determine that Section 8905-a and the New York Liquor Law is unconstitutionally vague as to professional MMA. It cites the uncertainty of state officials as to the application and interpretation of the law. It notes oral argument in which the Attorney General for New York admitting that professional MMA could be sanctioned by an Exempt Organization under the law. The AG later explained away his statement. Zuffa also argues that the law is vague and it encourages arbitrary and discriminatory enforcement.
Zuffa’s moving papers hammer away that the law banning professional MMA has many interpretations and these multiple interpretations even trip up those that enforce the rules.
The following summary is just a cursory look at the papers and does not even delve into the deposition excerpts and exhibits. At this point, we’ll wait on the opposition briefs which should include more declarations and deposition transcript excerpts. And then there will be more in the reply to the opposition briefs. The final pleadings for the motion will not be filed until early September. Based on the amount of paper to read, one might not expect a decision until December, or early 2015.
But let’s assume New York wins and the case is dismissed. Zuffa will have to consider its options which may include an appeal to the Circuit Court on the decision. It would cost more money and take much longer and unless there is movement in Albany, no MMA in New York.
But what if the Court sides with Zuffa and grants its motion for summary judgment? This would mean that the law banning MMA will be determined unconstitutional and essentially strike down the law. One might expect a stay and/or the state of New York filing a preliminary injunction to stay the ruling in an effort to appeal the ruling. The effect of an injunction would be a way to prevent pro MMA in the state before an appeal to the ruling is heard by another Court. The last time most of us heard about a preliminary injunction was in the Eddie Alvarez case. In the meantime, legislators in New York that are anti-pro MMA could draft new legislation which would clarify the vagueness issue and have it ready for Albany in 2015. We could be completely off on this scenario and we haven’t even seen opposition briefs but I thought I’d throw this theory out there.
MMA Payout will have more on these motions in the coming days.
July 29, 2014
MMA Payout has learned from a Nielsen source that Saturday’s UFC on Fox 12 main card received a Live plus Same Day rating of 2.5 million viewers. The rating falls in line with Fox shows during the summer and is better than UFC on Fox 11’s rating this past April.
UFC on Fox 1: 5.7 million
UFC on Fox 2: 4.57 million
UFC on Fox 3: 2.25 million
UFC on Fox 4: 2.36 million
UFC on Fox 5: 3.41 million
UFC on Fox 6: 4.22 million
UFC on Fox 7: 3.3 million
UFC on Fox 8: 2.38 million
UFC on Fox 9: 2.9 million
UFC on Fox 10: 3.22 million
UFC on Fox 11: 1.98 million
UFC on Fox 12: 2.5 million
UFC on Fox 12 received a 1.5 rating and 3 share. The peak occurred during the main event overrun at 3,427,000 viewers. The event featuring Robbie Lawler defeating Matt Brown was first in all of the key demos for the organization. Men 18-34 (1.3), Men 18-48 (1.5), Men 25-54 (1.7) and Adults 18-49 (1.0).
The ratings improved slightly from the summer event for Fox the past two years. Notably, Lawler was on the July 2013 show last year too. And, even though there was a title fight in 2013, it was Demetrious Johnson. It seemed like the Lawler-Brown fight had a little more interest. It also may have helped that the prelims were on the network as well. The prelims scored an average of 1.3 million and the audience built through the evening.