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1
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-6956Plaintiff, )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 RageFull Contact Fighting, LLC and Chance Farrar:
The Parties
 1.
 
Bellator Sport Worldwide, LLC (“Bellator”) is a Delaware limited liabilitycompany with its principal place of business in Chicago, Illinois 60654.2.
 
Desert Rage Fighting, L.L.C. (“Desert Rage”) is an Arizona limited liabilitycompany with its principal place of business in Yuma, Arizona.3.
 
Chance Farrar (“Farrar”) is an individual who, on information and belief, residesin the state of Arizona. Bellator is informed and believes that Farrar is the principal of DesertRage.
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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 interestand costs, and is between citizens of different states.5.
 
Venue is proper in this judicial district pursuant to 28 USC § 1332(a) becauseBellator’s principal place of business is within this district, a substantial part of the events oromissions giving rise to the claim for damages to the plaintiff occurred in this district, andDefendants knowingly and purposefully directed their conduct toward Bellator’s business inIllinois.
FACTSBellator’s Business in Illinois
6.
 
Bellator is a promoter of Mixed Martial Arts (“MMA”) fights, tournaments, andrelated events through its organization known as Bellator Fighting Championships.7.
 
Bellator is a well-respected MMA promotional organization that broadcasts toaudiences comprised of hundreds of thousands of viewers per week, nationally andinternationally. It is well-known throughout the MMA industry that Bellator is based in Illinoisand conducts its business from Illinois.8.
 
Eleven of Bellator’s 17 full-time employees are exclusively based in Chicago,conducting their daily functions from Chicago and traveling to and from Chicago for Bellatorevents.
Desert Rage
9.
 
Desert Rage is an MMA promotional organization based in Arizona that haspromoted MMA events in Mexico, California, and Arizona.
Case: 1:11-cv-06956 Document #: 1 Filed: 10/03/11 Page 2 of 13 PageID #:2
 
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10.
 
Defendants employ and/or contract with individuals who act on behalf of DesertRage and Defendant Farrar in an agency capacity with respect to promoting Desert Rage MMAevents.11.
 
Defendants maintain an interactive worldwide website through which theycommunicate with fans. Fans are able to participate in discussion forums on the website. Thiswebsite 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 exclusivepromotional agreements with Bellator.13.
 
Desert Rage also maintains two additional web pages on Facebook.com andMyspace.com. In addition to possessing the communication capabilities of Defendants’ website,both web pages allow non-Arizona based “Friends” to communicate with Defendants and poston their “Wall.”
Bellator’s 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 eventmarket.16.
 
Previously, Bellator engaged Farrar to aid in promoting Bellator’s April 16, 2011show in Yuma, Arizona.
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