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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION


)
)
)
BELLATOR SPORT WORLDWIDE, )
L.L.C., a Delaware limited liability )
corporation, )
) Civil Action No. 11-cv-6956
Plaintiff, )
v. )
)
DESERT RAGE FULL CONTACT )
FIGHTING, L.L.C. an Arizona limited )
Liability Corporation, and )
CHANCE FARRAR, an individual, )
)
Defendants. )


COMPLAINT

Bellator Sport Worldwide, LLC, states the following as its complaint against Desert Rage
Full Contact Fighting, LLC and Chance Farrar:
The Parties
1. Bellator Sport Worldwide, LLC (Bellator) is a Delaware limited liability
company with its principal place of business in Chicago, Illinois 60654.
2. Desert Rage Fighting, L.L.C. (Desert Rage) is an Arizona limited liability
company with its principal place of business in Yuma, Arizona.
3. Chance Farrar (Farrar) is an individual who, on information and belief, resides
in the state of Arizona. Bellator is informed and believes that Farrar is the principal of Desert
Rage.

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Venue and Jurisdiction

4. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
Section 1332 because the matter in controversy exceeds the sum of $75,000, exclusive of interest
and costs, and is between citizens of different states.
5. Venue is proper in this judicial district pursuant to 28 USC 1332(a) because
Bellators principal place of business is within this district, a substantial part of the events or
omissions giving rise to the claim for damages to the plaintiff occurred in this district, and
Defendants knowingly and purposefully directed their conduct toward Bellators business in
Illinois.
FACTS

Bellators Business in Illinois

6. Bellator is a promoter of Mixed Martial Arts (MMA) fights, tournaments, and
related events through its organization known as Bellator Fighting Championships.
7. Bellator is a well-respected MMA promotional organization that broadcasts to
audiences comprised of hundreds of thousands of viewers per week, nationally and
internationally. It is well-known throughout the MMA industry that Bellator is based in Illinois
and conducts its business from Illinois.
8. Eleven of Bellators 17 full-time employees are exclusively based in Chicago,
conducting their daily functions from Chicago and traveling to and from Chicago for Bellator
events.
Desert Rage
9. Desert Rage is an MMA promotional organization based in Arizona that has
promoted MMA events in Mexico, California, and Arizona.
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10. Defendants employ and/or contract with individuals who act on behalf of Desert
Rage and Defendant Farrar in an agency capacity with respect to promoting Desert Rage MMA
events.
11. Defendants maintain an interactive worldwide website through which they
communicate with fans. Fans are able to participate in discussion forums on the website. This
website also allows Defendants to disseminate information related to Desert Rage events,
including photographs, news, and information about Defendants promotional sponsors,
including non-Arizona-based entities such as Budweiser and Full Throttle Energy Drink.
12. The Desert Rage website also disseminates information about past Desert Rage
Champions, including two individual fighters who are currently under worldwide exclusive
promotional agreements with Bellator.
13. Desert Rage also maintains two additional web pages on Facebook.com and
Myspace.com. In addition to possessing the communication capabilities of Defendants website,
both web pages allow non-Arizona based Friends to communicate with Defendants and post
on their Wall.
Bellators Initial Engagement With Defendant Farrar
14. Bellator has established good relations with its local contractors, venues, fighters,
and other affiliates in each of the local markets it conducts events in, including Arizona.
15. To aid with local grassroots promotion of Bellator events outside of Illinois,
Bellator will occasionally engage promoters who have previously operated in the local event
market.
16. Previously, Bellator engaged Farrar to aid in promoting Bellators April 16, 2011
show in Yuma, Arizona.
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17. As part of that engagement, Farrar communicated often with Bellator employees
based in Chicago and was paid for his services by Bellator using its Chicago-based bank
accounts.
18. As part of the services he rendered in connection with Bellators April 16 event,
Farrar gained intimate familiarity with Bellators business, including its method for setting up
events, and recruiting talent for its shows.
19. Farrar also had substantial involvement with, and developed an understanding of,
Bellators process of signing fighters for its events, including, but not limited to, Bellators
process and rationale for signing certain fighters, its philosophy behind ticket sales, as well as
each fighters production value.
20. As part of his role in the April 16 event, Farrar saw Bellators fighter contracts,
which included material payment terms that Bellator negotiates with fighters as part of an often-
lengthy bargaining process.
21. Farrar also was privy to the long-term promotional contract terms of Bellators
agreements with fighters, including its obligations to fighters under those contracts and its
methods and systematic means of meeting those obligations.
Bellators October 22, 2011 Event
22. In early August of 2011, Bellator began recruiting talent for and promoting its
October 22, 2011 show, Bellator Fighting Championships 55 (BELLATOR 55), which is to be
held in Yuma, Arizona at the Cocopah Casino and Resort.
23. Bellator did not engage Desert Rage to assist with BELLATOR 55.
24. All of the planning for BELLATOR 55 and much of the work related to it is
occurring in Bellators Chicago headquarters. The production costs of BELLATOR 55 exceed
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$500,000. The event will air live on the MTV2 television network, EPIX television network,
and Spike.com.
25. More than half of the 18 fighters committed to participating in Bellators October
22 event reside outside of Arizona.
Defendants Unlawful Behavior Related to Bellator BELLATOR 55
26. On August 23, 2011, in an effort to disrupt Bellators previously scheduled event,
Defendants announced that Desert Rage would hold an MMA event entitled Desert Rage X on
October 22, 2011, the same night as BELLATOR55, at Paradise Casino in Winterhaven,
California a mere nine miles away from the BELLATOR 55 event site.
27. On or around August 31, 2011, Bellator learned that Defendants had spoken to
fighters and/or the managers of fighters already under exclusive promotional contracts with
Bellator for BELLATOR 55, offering a higher sum of money to these fighters if they would
abandon their signed commitment to Bellator and instead participate in Defendants Desert Rage
X show.
28. Defendants were aware that these fighters were already under contract to Bellator
at the time they attempted to induce the fighters to breach their contracts with Bellator.
29. In response to this improper and damaging conduct, Bellator sent a letter via
email and certified mail to Defendant Farrar on September 1, 2011, demanding that he and his
organization cease and desist all communications with Bellator-contracted fighters as well as any
conduct that could interfere with Bellators existing contracts. A copy of the September 1, 2011
letter is attached as Exhibit A.
30. Neither Farrar nor any representative of Desert Rage responded to the September
1, 2011 letter.
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31. On September 12, 2011, Bellator learned that Defendants had told multiple parties
that BELLATOR 55 was cancelled. Upon information and belief, Defendants knowingly
misrepresented the status of BELLATOR 55 to persuade important local fighters with whom
Bellator was negotiating, as well as others currently under contract with Bellator, to participate in
the Desert Rage X show instead of the BELLATOR 55 event.
32. At the time of Defendants misrepresentations, Bellator had a reasonable
expectation that the fighters with whom it was negotiating were ready to execute contracts with
Bellator for their participation in BELLATOR 55.
33. After Defendants began spreading false information to Bellators prospects, these
fighters ceased or drastically reduced their engagement in negotiations with Bellator.
34. Defendants also knowingly spread this false information about BELLATOR 55 to
others in the MMA industry that would ordinarily be relied upon for support for ticket sales,
local labor, and sponsorships for the event.
35. Due to the damaging nature of Defendants improper conduct, Bellators General
Counsel contacted Farrar via telephone on September 13, 2011.
36. In that conversation, Farrar admitted to receiving Bellators September 1, 2011
letter. Bellator made clear to Farrar in this conversation that his conduct and the conduct of his
agents acting on behalf of Desert Rage was improper, tortious, damaging, and actionable.
Bellator informed Farrar in unequivocal terms that he must cease and desist all such behavior. In
this conversation, Farrar denied that he, personally, had ever stated that BELLATOR 55 had
been canceled and attributed such statements to his agents and employees.
37. Within days after the September 13 conversation, Bellator continued to be
informed that Defendants were continuing their improper conduct.
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38. The impact on Bellator is discernible. Instead of focusing on promoting ticket

sales and sponsorships for BELLATOR 55, it has had to devote substantial efforts instead to
remedying the misinformation that Defendants have put into the marketplace. In addition,
Bellator has lost the interest of prospective fighters who otherwise would have likely signed with
Bellator. Bellator also is concerned that other, signed fighters will not appear for the Bellator
event either because they believe it has been canceled or because they were offered more money
to fight in the Desert Rage event.
39. Bellators ticket sales will also be impacted, as well as its ability to get the
peripheral support for ticket sales, labor and sponsorships, as a result of Defendants conduct.

COUNT I: INTENTIONAL INTERFERENCE
WITH CONTRACTUAL RELATIONS

40. Bellator repeats and realleges the previous paragraphs of this Complaint as if fully
set forth herein.
41. Bellator has existing contracts with multiple fighters for their participation in
BELLATOR 55.
42. Upon information and belief, Farrar used his knowledge of material aspects of
Bellators business for his own and Desert Rages benefit in order to unfairly compete with
Bellator. With this information, Farrar, or at Farrars direction, Desert Rage and its agents,
contacted fighters and/or their managers with the express purpose of offering them more money
than Bellator had committed to pay if they would breach their contracts with Bellator.
43. Upon information and belief, Defendants knowingly published and/or conveyed
to multiple parties the erroneous information that Bellators BELLATOR 55 event was
cancelled.
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44. At the time that they acted in this manner, Defendants were aware of Bellators
existing agreements with the fighters and knew that BELLATOR 55 was neither cancelled nor
likely to be cancelled.
45. Defendants willfully and knowingly engaged in this improper conduct to coerce
and induce the fighters or their managers to breach their contracts with Bellator.
46. This conduct constitutes tortious interference with contract under Illinois law.
47. Bellator has been damaged by this conduct.
48. Bellator has been unable to stop Defendants from these unlawful practices. Due
to the proximity of the event, Defendants are causing irreparable harm by their actions.

COUNT II: INTENTIONAL INTERFERENCE WITH PROSPECTIVE
ECONOMIC ADVANTAGE

49. Bellator repeats and realleges the previous paragraphs as if fully set forth herein.
50. Bellator has been in intense negotiations with multiple fighters related to their
participation in BELLATOR 55.
51. Bellator had a reasonable expectation that these fighters were imminently ready to
execute contracts with Bellator for their participation in BELLATOR 55.
52. Defendants knowingly and willfully conveyed and published to multiple parties in
the MMA industry false information regarding the cancellation of BELLATOR 55 so that
Bellators prospective fighters would sign with Desert Rage.
53. After Defendants improper conduct, these fighters drastically reduced or ceased
their engagement in negotiations with Bellator.
54. Defendants conduct has and will continue to jeopardize Bellators ability to sign
additional fighters for the event, and has and will continue to impact ticket sales for BELLATOR
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55 and Bellators reasonable expectation and ability to engage affiliates and sponsors for the
event.
55. Defendants conduct constitutes an intentional interference with Bellators
prospective economic advantage under Illinois law.
56. Bellator has suffered and will continue to accrue damages from Defendants
improper behavior in the form of additional resources needed to secure talent, drastic drops in
prospective ticket sales, among other damages at law.
57. Bellator has been unable to stop Defendants from these unlawful practices. Given
the proximity of the event, Defendants are causing irreparable harm.

COUNT III: NEGLIGENT INTERFERENCE WITH PROSPECTIVE
ECONOMIC ADVANTAGE

58. Bellator repeats and realleges the previous paragraphs as if fully set forth herein.
59. To the extent Defendants improper conduct was not willful, that conduct was
unreasonably reckless, without regard to Bellators rights and any foreseeable injuries to Bellator
proximately resulting from Defendants conduct.
60. Bellator has suffered and will continue to be damaged from Defendants improper
behavior.
61. Bellator has been unable to stop Defendants from these unlawful practices. Due
to the proximity of the event, Defendants are causing irreparable harm by their actions.

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COUNT IV: VIOLATION OF THE ILLINOIS UNIFORM DECEPTIVE

TRADE PRACTICES ACT

62. Bellator repeats and realleges the previous paragraphs of this Complaint as if fully
set forth herein
63. Bellator is a well-respected MMA promotional organization that broadcasts to
well over 250,000 viewers per week, nation-wide.
64. Bellator has established good relations with its local contractors, venues, fighters,
and other affiliates in the Arizona market and throughout the country.
65. Defendants knowingly and willfully conveyed and published to those in the
MMA industry and related businesses false information regarding the cancellation of
BELLATOR 55.
66. Defendants conduct has damaged Bellators relationships with these parties,
lowering its business reputation in the eyes of those parties, and it continues to damage Bellators
ability to recruit talent, contract with labor, and sell tickets in advance of BELLATOR 55.
67. Defendants conduct constitutes a violation of Illinois Uniform Deceptive Trade
Practices Act, 815 ILCS 510/2(a)(8) and (12).
68. Bellator has suffered and will continue to suffer damages from Defendants
improper conduct. Bellator has been unable to stop Defendants from these unlawful practices.
Due to the proximity of the event, Defendants are causing irreparable harm.

COUNT V: COMMON LAW UNFAIR COMPETITION
69. Bellator repeats and realleges the previous paragraphs of this Complaint as if fully
set forth herein.
70. Defendants aforesaid conduct set forth in Counts I through IV of this Complaint
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constitutes unfair competition in violation of the common law of the several states, including the
State of Illinois.
WHEREFORE, Bellator requests that the Court award it the following relief:
1) An order enjoining Desert Rage and Farrar from proceeding with their October 22
event, and further enjoining Defendants from holding any MMA event within 50 miles of Yuma,
Arizona until after October 25, 2011.
2) An order enjoining Desert Rage and Farrar, and each of their officers, directors,
agents, servants, employees, attorneys, and all others in active concert or participation with any
of them and who receive actual notice of the order, from:
a) Directly or indirectly contacting any talent or contractors currently bound by
exclusive contracts with Bellator for BELLATOR 55;
b) Directly or indirectly contacting any talent or contractors of any kind known to
be in the process of negotiating with Bellator for BELLATOR 55;
c) Publishing, misleading, confusing, or conveying in any way, shape or form,
whether through direct communication or conduct, false information of any kind related
to Bellator or BELLATOR 55;
d) Using confidential Bellator information to accomplish any of the unlawful
conduct set forth in paragraphs (a) through (c);
e) Aiding or assisting any persons or entities in engaging in any of the acts or
things prohibited in paragraphs (a) through (d).
3) Actual damages greater than $75,000 in an amount to be proven;
4) Any profits or gains to Defendants or their affiliates resulting from Defendants
unlawful conduct;
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5) Exemplary or punitive damages in a sum sufficient to deter future acts of
interference, unfair competition and deceptive trade practices;
6) Attorneys fees and costs pursuant to the Illinois Uniform Deceptive Trade
Practices Act; and
7) Such other relief as the Court deems just and equitable.

JURY DEMANDED


Respectfully submitted,
BELLATOR SPORT WORLDWIDE, LLC


/s/ Patrick J. Lamb
One of the attorneys for Bellator Sport
Worldwide, LLC


Patrick J. Lamb
Nicole Nehama Auerbach
Valorem Law Group LLC
35 East Wacker Drive
Suite 3000
Chicago, IL 60601
312-676-5460

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CERTIFICATE OF SERVICE

I certify that a copy of this COMPLAINT and CIVIL COVER SHEET was filed electronically
with the United States Court for the Northern District of Illinois, Eastern Division, on this 3
rd
day
of October, 2011. Notice of this filing will be sent to the parties by operation of the Court's
electronic filing system. Parties may access this filing through the Court's system.

/s/ Patrick J. Lamb
Patrick J. Lamb
VALOREM LAW GROUP LLC
35 E. Wacker Drive, Ste. 3000
Chicago, IL 60601
312-676-5460

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EXHIBIT A
Case: 1:11-cv-06956 Document #: 1-1 Filed: 10/03/11 Page 1 of 2 PageID #:14
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SepLember 1, 2011

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Chance larrar
8636 L. 24Lh Lane
?uma, AZ 83363
!
"#$!%#&'#!&()!*#'+',

uear Chance,

l undersLand LhaL you have been speaklng Lo and negoLlaLlng wlLh flghLers who are currenLly under
conLracL Lo 8ellaLor llghLlng Champlonshlps, persuadlng Lhem Lo breach Lhelr conLracL wlLh 8ellaLor
and flghL ln a show LhaL you are promoLlng.

?ou have now been placed on noLlce LhaL you -.',! /#&'#! &()! ,0+'! 1#0&2+34! +--#)+&,#56. lL wlll
resulL ln a lawsulL agalnsL you. All flghLers under conLracL wlLh 8ellaLor - even a shorL-Lerm conLracL -
are prohlblLed from parLlclpaLlng ln any oLher flghLs for any oLher promoLlonal organlzaLlon. Lven
negoLlaLlng wlLh 8ellaLor flghLers abouL Lhe posslblllLy of flghLlng for you glves Lhe company clear
grounds Lo walk lnLo llllnols federal courL and flle sulL agalnsL you lmmedlaLely. noL only would any
[udge easlly granL 8ellaLor a courL order prohlblLlng you from engaglng any 8ellaLor flghLers, buL you
would also be responslble for paylng 8ellaLor's aLLorney fees and cosLs relaLed Lo our lawsulL, plus any
damages. And l assure you, seeklng an urgenL courL order llke Lhls can easlly resulL ln fees, cosLs, and
damages exceedlng $100,000.

73!1#!/5#&4: Should 8ellaLor recelve even Lhe sllghLesL lndlcaLlon LhaL you are conLlnulng Lo negoLlaLe
wlLh any 8ellaLor flghLer, Lhe company wlll lmmedlaLely flle sulL wlLhouL provldlng you any furLher
noLlce whaLsoever.

?ou have been advlsed.

Slncerely,


1racey S. LeseLar
Ceneral Counsel
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