This firm represents Don King Productions, Inc. (“DKP”), the exclusive worldwide
promoter of the World Boxing Council (“WBC”) Cruiserweight Champion, Noel Mikaelian
(“Mikaelian”). DKP has a legally binding and valid Promotional Agreement (“Agreement”) with
Mikaelian that grants DKP the exclusive worldwide rights to engage Mikaelian’s services for any
and all professional boxing matches.
It has come to DKP’s attention that TKO Group Holdings, Inc. and Zuffa Boxing
(collectively, “TKO/Zuffa”) have engaged the professional boxing services of Mikaelian, without
DKP’s permission, consent or authorization, to engage in a bout against Jai Opetaia (“Opetaia”)
on September 12, 2026 in Las Vegas, NV (the “Bout”). TKO/Zuffa’s actions are outrageous and
a clear tortious interference with DKP’s Agreement.
Based on, inter alia, emails between you and DKP’s legal counsel, Carl Lewis, Esq. (“Mr.
Lewis”), there is absolutely no doubt that TKO/Zuffa was and is aware that DKP is Noel’s
promoter.
I understand that you were personally involved in discussions with Mr. Lewis regarding a
potential fight or multi-fight deal for Mikaelian, which would include a fight with Opetaia, and
that no agreement was consummated. It is particularly disturbing to know that TKO/Zuffa’s Chief
Operating Officer, Harrison Whitman, Esq., and the head of TKO/Zuffa, Dana White, had at least
one virtual conference with DKP’s President, Mr. Don King, and Mr. Lewis in an effort to secure
a Provision of Services (“POS”) deal for Mikaelian, again which included a fight with Opetaia.
Although no deal was reached, it is indefensible for Zuffa/TKO to completely ignore the DKP
Agreement, the promoter-fighter relationship between DKP and Mikaelian, and circumvent DKP
and engage the services of Mikaelian for the Bout with Opetaia.
TKO/Zuffa cannot justify its actions by claiming that you negotiated with Mikaelian’s
Manager, Anthony Girges and Mikaelian’s attorney, James Greeley, Esq., as again only DKP can
negotiate and enter into an agreement with a third party for Mikaelian’s services. The DKP
Agreement grants Mikaelian the right to “discuss and explore” other fight opportunities, but only
in consultation with DKP and under no circumstance can Mikaelian enter into an agreement with
another party for his professional services without the expressed consent and permission of DKP.
As stated above, TKO/Zuffa’s actions in promoting Mikaelian, without DKP’s knowledge,
consent or permission, is a clear tortious interference of the Agreement. DKP does not and has not
granted TKO/Zuffa permission to engage the services of its fighter, Mikaelian.
To be unequivocally clear, TKO/Zuffa’s actions constitute a knowing, intentional and
unjustified tortious interference with the Agreement. Any contracts that Mikaelian has entered into
or shall enter into for his professional services as a fighter, without the express, written consent of
DKP are void. The announced September 12, 2026, Bout between Mikaelian and Opetaia cannot
go forward. TKO/Zuffa must immediately cancel the Bout between Mikaelian and Opetaia and
announce such cancellation in the media immediately. Furthermore, TKO/Zuffa cannot engage
Mikaelian for any match without DKP’s express, written consent and permission.
DKP has not and does not give TKO/Zuffa permission to negotiate with Mikaelian or to
engage him, directly or indirectly, in any professional fights. TKO/Zuffa is hereby directed to
immediately cease and desist its actions and to have no further communications and/or business
dealings of any kind with Mikaelian. Any communications, discussions and dealings with Mikaelian for his professional services must be done by DKP.
Please confirm to me that you have received this letter by return email and that TKO/Zuffa
will comply with this demand.
This letter should not be construed as a waiver of any rights, and DKP hereby expressly
reserves the right to pursue any and all remedies available at law or in equity.
Please be governed accordingly.