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Judge warns missing cell phones and records represent ‘sanctionable offenses’ in latest UFC anti-trust case
Ryan Harkness
Sun, February 8, 2026 at 8:49 PM UTC
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5 min read
UFC heads Dana White and Hunter Campbell were in a Nevada court this past week answering questions regarding the lack of disclosure materials turned over for another series of anti-trust lawsuits launched by fighters.
Just like Le vs. Zuffa — which ended in fighters from 2012 to 2017 getting a $375 million settlement — Johnson v. Zuffa accuses the UFC of using monopsony power to artificially depress fighter wages, this time from 2017 onward. Cirkunov v. Zuffa argues that UFC fighters who signed class action arbitration clauses should still be able to participate in Johnson v. Zuffa, and Davis v. Zuffa represents fighters outside the UFC who also claim they were harmed by UFC’s anti-competitive behavior.
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All of these anti-trust cases are being handled together by Judge Richard Boulware, the same judge that oversaw the settlement of Le vs. Zuffa. According to fighter lawyers, years worth of communications from White, Campbell, and UFC lawyer Tracy Long were completely missing from discovery documents turned over, leading to this past week’s spoliation hearing.
If the UFC doesn’t manage to dig that data up, they could be on the receiving end of serious legal repercussions from Judge Boulware.
Those listening in on the spoliation hearing that took place over February 11th and 12th 2026 weren’t treated to much of an exciting courtroom drama, even when UFC CEO Dana White and CBO Hunter Campbell took the stand. Instead it was a lot of jousting back and forth about who did what work related to fighter contracts, how those people communicated with each other, and what happened to old phones that various employees used.
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The goal of the hearing was to establish why five years worth of communications from White and Long were not turned over to fighter lawyers. There was also a phone from Campbell that was never scanned which plaintiffs alleged was used to send over 3000 messages to UFC matchmakers. All in all, the testimony provided painted a picture of the UFC being extremely sloppy with their legal responsibility to maintain and turn over records for the court.
Legal expert John Nash was on hand in Nevada to witness the hearing and discussed the potential outcomes of the spoliation hearing on his Substack podcast.
“The judge is probably going to lay some sort of sanction punishment on the plaintiffs,” Nash said on Hey Not The Face. “He said these are sanctionable offenses. The question is: on a spectrum of what he can do and a spectrum of how much fault he finds with him, what will he do?”
The UFC claimed that Dana White is no longer involved with anything regarding UFC fighters, contracts, or matchmaking which means the missing years of communication don’t matter. Boulware’s questioning of White suggested he didn’t quite buy that argument.
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“If the judge decides that this material is really relevant to the case, that there is material in there that’s important,” Nash said. “Not just a small amount, but a large amount that’s very important that would demonstrate the UFC’s business workings, and it’s missing. Then how do you run a case? How do the plaintiffs make their case? How does the judge make determinations? How does the jury?”
“The judge has to make a determination about these arbitration agreements,” Nash said of Cirkunov v. Zuffa. “He has to make a decision on these arbitration class action waivers, and he could basically say, ‘I have to decide with the [fighters] because the material that could possibly either prove the plaintiff’s case or prove the defendant’s case is missing.'”
“‘And because it’s missing due to gross negligence or malicious intent by the [UFC], I am forced through adverse inference to weigh it on the side of the plaintiffs in that case. I have to throw out these arbitration agreements and class action waivers under Nevada law.’ And so all the fighters … they are now back in the Johnson class.”
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The more fighters are represented by the class, the more money is at stake as this anti-trust case moves forward. The $375 million Le v. Zuffa settlement would be a small amount compared to how much money Johnson v. Zuffa fighters could sue for. And that adverse inference due to sanctioned discovery violations could haunt UFC through an actual trial.
“If it goes to trial,” Nash said. “[The judge] could turn to the trial and say, ‘Because this material is missing, I think you should have an adverse inference that you, the jury, are free to interpret any time that there’s an argument based on material that we do not have available. You can weigh it that it’s the most adverse to the [UFC] and most beneficial to the [fighters].”
Judge Boulware gave UFC lawyers another 30 days to sort out the mess of missing cell phones and records, but it sounds like the missing years worth of Dana White communication will not be recovered. How the judge will react to this is unknown, but he made it clear that he is extremely unhappy about how poorly the UFC kept their records despite being under court order to save them.
The legal fallout from his ruling on the subject could be massive, and may push the UFC towards yet another multi-million dollar settlement with its fighters.