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STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
CORPORATIONS, SECURITIES & COMMERCIAL LICENSING  
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PUBLIC HEARING  
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THURSDAY, DECEMBER 16, 2021  
AT ABOUT 1:20 P.M.  
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2407 NORTH GRAND RIVER AVENUE  
LANSING, MICHIGAN  
SUN CONFERENCE ROOM  
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RE: Administrative Rules for Unarmed Combat  
Rule Set 2021-131 LR  
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HEARING FACILITATOR:  
MACKENZIE JONES  
Corporations, Securities &  
Commercial Licensing Bureau  
2407 N. Grand River Avenue  
Lansing, Michigan 48906  
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REPORTED BY: Lori Anne Penn, CSR-1315  
Penn Reporting, LLC - lori.penn@yahoo.com  
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I N D E X  
2 Opening - Mackenzie Jones  
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4 COMMENTS:  
PAGE  
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FRANK GARZA  
COLLIN ROGERS (MATEE TONGBUA)  
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8 Closing - Mackenzie Jones  
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Lansing, Michigan  
Thursday, December 16, 2021  
At 1:20 p.m.  
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(Public hearing commenced pursuant to due notice.)  
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MR. JONES: Good afternoon, everyone.  
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This is a public hearing on the proposed administrative  
rule set entitled "Unarmed Combat". This hearing is  
being conducted under the provisions of the Michigan  
Unarmed Combat Regulatory Act and under the authority of  
the Administrative Procedures Act, and on behalf of the  
Department of Licensing and Regulatory Affairs' Michigan  
Unarmed Combat Commission.  
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This hearing is being called to order at  
approximately 1:20 p.m. on Thursday, December 16, 2021,  
at the MRA Building, 2407 Grand River Avenue, Lansing,  
Michigan 48906, in the Sun Conference Room. Thank you  
guys for coming.  
The notice was published on December 1,  
2021, issue of the Michigan Register, and the notice of  
public hearing was also published in the following three  
newspapers of general circulation:  
The first, The Grand Rapids Press on or around  
November 18, 2021;  
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The second, Ann Arbor News on or around  
November 18, 2021;  
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And the third, The Marquette Mining Journal on or  
around November 15, 2021.  
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This notice and rule -- the notice and  
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rulemaking documents were also posted on the Office of  
Regulatory Reinvention's website at www.michigan.gov/orr.  
My name is Mack Jones, and I will be  
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facilitating the public hearing today.  
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We are here to receive your comments and  
recommendations on the proposed rules. Testimony  
presented at this hearing or received in writing will be  
reviewed for consideration of any changes or additions to  
the proposed rules and will become part of the public  
record.  
If you wish to speak, please make sure  
you have indicated your willingness to speak on the  
sign-in sheet; we will call on speakers in the order in  
which the names are listed on the sign-in sheet. When  
you come forward, please speak, identify yourself with  
your name, your organization you may represent, and both  
your mailing and email address so that this information  
can be transcribed into the hearing report.  
If you did not bring a prepared  
statement, the public comment period will remain open  
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until 11:59 p.m. on Thursday, January 6, 2022, for  
additional written comments. These written comments may  
be submitted to me by email at jonesm52@michigan.gov, or  
by mailing your comments to the Michigan Unarmed Combat  
Commission, P.O. Box 30018, Lansing, Michigan 48909.  
To begin with, Mr. Garza wished to speak.  
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Come up here if you'd like.  
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MR. GARZA: Thank you. My name is Frank  
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Garza; address, 1524 Michigan Boulevard, Lincoln Park,  
Michigan 48146; email, four letters, J- as in John R- as  
in Robert G- as in girl, Z as in zebra @hotmail.com. I'm  
here as a licensed Michigan licensed boxing referee.  
I've been a licensed referee since 1984,  
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I am licensed as a judge and a referee for professional  
boxing. I served on the Michigan Athletic Board of  
Control from 1992 to 1994. This board is the predecessor  
of the Unarmed Combat Commission. I was awarded a  
special tribute from Governor Engler for the rewrite and  
update of rules, and also awarded a special tribute from  
Governor Snyder in assisting the Unarmed Combat  
Commission with Dr. Jim Lever, who was the chairman.  
During my tenure, I co-authored Michigan Officials  
Handbooks and held training clinics for officials. As a  
referee, I've officiated world championship fights and  
major title bouts totaling over 120 for every recognized  
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rule sanctioning body in 20 U.S. states and the District  
of Columbia, as well as 17 countries around the world. I  
currently sit on the Officials Committee for the North  
American Boxing Federation and the World Boxing Council.  
I was awarded the 1996 IBA Boxing Referee  
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of the Year, I was named in the top ten referees by Ring  
Magazine in 2002, and I was named by the World Boxing  
Council as one of the top 50 boxing referees in the  
entire history of boxing. I'm an inductee in the Lincoln  
Park Sports Hall of Fame, the Delta St. John Alumni Hall  
of Fame, and have recently been inducted into the  
National Boxing Hall of Fame.  
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I apologize for bringing this all out,  
and there is more that I can add, but I'm hoping this is  
enough to have everyone here listen to my public comments  
and take into consideration what I have to say. Please  
do not take any comment I make today as anything  
negative, for on the contrary, I love this sport and I  
owe a lot to it for it has allowed me many opportunities  
over the past 37 years to experience and be a part of  
events that only people dream of.  
Now, the Department has stated that the  
proposed rules will improve the reliability of event  
officials and prevent the appearance of impropriety, and  
that other changes include more flexibility in attaining  
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a professional license. I'll comment a little more about  
that on the end. But on the proposed rule changes, I  
have comments and concerns about these.  
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Under definitions, contest officials are  
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defined as a referee, judge, and timekeeper, but we also  
need to include and license the following as well: The  
doctors, the ring announcers, the DJs, and the ring card  
girls. Each one of these play a role and they have  
responsibilities whose actions need to be held  
accountable for the conduct of a professional boxing  
show.  
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For example, a doctor can influence the  
referee on when to stop a bout and not be questioned or  
scrutinized. Ring announcers, if they're not held  
accountable, they can incite a crowd, they can create an  
unsafe environment by making comments not related to the  
event on hand, they can be disruptive to the flow of the  
event, and this happens quite a bit. And we had a very,  
very bad situation at a fight recently in Warren. DJs  
can be disruptive. They can play nonfamily-friendly  
material, they can also create an unsafe environment with  
the music they play, and they make it nearly impossible  
to carry on official ringside business prior to the show.  
Ring card girls, luckily not now, but in the past they  
have been known to engage in certain customer-friendly  
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services, and I don't want to see that come back again.  
Now, some states license the following, and I feel that  
we should take a hard look into that.  
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Another definition change that I have a  
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concern with is hanging helplessly. The ropes prevent a  
boxer -- and I'd like to see that changed to the ropes  
prevent a boxer from going to the canvas. This then  
takes into account if a boxer is hit, falls back, and the  
ropes prevent them from going down.  
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Under the licensing requirements, the  
word competence came up, and that needs to be defined. I  
mean I've known boxers who are 0 and 3 and they were  
better boxers that had a record of 5 and 0, and it was  
all based on who they lost to.  
Now, when it comes to licensing, I'd also  
like to see a requirement that a boxer must be licensed  
before he can sign a contract to compete in Michigan, and  
that a promoter must have a signed contract between two  
boxers who are licensed before they can advertise the  
bout; this would eliminate a lot of wasted time making  
bouts and holding a boxer accountable, and gives the  
ability to hold a boxer accountable if they fail to show  
up. In addition, a ticket buyer would know what he is  
buying and not be disappointed once he's inside the  
venue. Right now it's really a bait-and-switch program.  
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Under the contest official, the term duty  
of impartiality is mentioned. Now, this concept is good,  
but the way it's written, not so much. I believe  
officials need a code of ethics, but I think we would be  
better served if we had a written code of ethics like  
those that the NABF, that's the North American Boxing  
Federation, and the World Boxing Council, as well as all  
the other world organizations have.  
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After reading through this section, I was  
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reminded when I was on the Michigan Athletic Board of  
Control by the attorney general who once told us, never  
make a rule that you can't enforce; and I ask, can this  
section really be enforced? I don't see any due process  
in this. And wouldn't the majority of the accusations be  
hearsay. In this section, it prohibits an event official  
in engaging in certain acts, such as not talking to a  
promoter 30 days before, during, or immediately after an  
event. Now, I can not ever recall in 37 plus years as a  
Michigan event official of knowing that I was going to be  
an official 30 days in advance.  
The placing of wagers, not that I gamble,  
I don't, and again, I understand the concept, but if I'm  
a boxing official, and I'm only a boxing official, this  
rule is saying that I can not wager on MMA, I can not  
wager on muay thai, I can not wager on kickboxing. I can  
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understand not making a wager on boxing, but what does  
that have to do on the other sports.  
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Lastly, with the promoter being  
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responsible for the assigning of officials, it's  
impossible to adhere to Rule No. 6 under this section  
unless the Act is changed, and I believe the Department  
of Licensing and Regulatory Affairs addresses this in  
their impact statement and cost-benefit analysis, and  
I'll again comment a little more on that at the end.  
Knockouts, boxing Rule No. 2, the  
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standing 8 count, we need to eliminate that, and change  
it to a mandatory 8 count that says the referee will give  
a mandatory count of 8 before allowing a boxer to resume,  
because there's times when you need just to stop your  
count at 4 and 5 and waive it over and get the doctor in,  
but the way it's written, it says that you have to  
complete the count of 8.  
The double knockdown rule decision. It's  
written as a double knockout, but I believe the  
Association of Boxing Commissions and all the major world  
organizations consider it a technical draw.  
Compensation for boxing officials. This  
has not been changed I'm going to say in 20 years, and  
I'd like to see the compensation raised up from $100 --  
I'll just do the referees; if you would like, I can mail  
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you my suggestions. Referees from 100 to 150, 150 to  
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200, 250 to 500, 350 to 700, and 700 to 1,000, and that's  
not out of line with other states in the near area.  
For my conclusion, when I look at our  
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handbook and our rule book for unarmed combat, it's kind  
of like looking at an owner's manual for a combination  
coffeemaker, toaster, and can opener, it's like this,  
(demonstrating with a brochure), very confusing, it's not  
friendly user. Boxing, MMA, muay thai, kickboxing, they  
may all fall under the auspices of the Unarmed Combat  
Commission, but they all need to have their own rule  
book. They all need to be addressed individually because  
they are individual, and regardless if the rules are  
redundant, they are different sports.  
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Now, I just used the word sporting, and  
again, bear in mind, I'm only speaking right now about  
boxing, but the word sport is a misnomer. Boxing is a  
business, a business that can generate hundreds of  
thousands to hundreds of millions of dollars when done  
properly. I'd like the Department or everyone here to  
ask themselves why do states like Nevada, California,  
Florida, and Texas have these huge mega fights. It's  
because they treat it like a business.  
Now, the State of Michigan has produced  
some of the biggest boxing stars ever, from Tommy Hearns  
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to James Toney, the Klichfil [sp] brothers, to Roger and  
Floyd Mayweather, but they've all made their fortunes  
outside of the State because we don't have the business  
environment here. Even I, for that matter. Do you know  
that when I work outside the State of Michigan, I make  
more in one fight than I do for the entire year that I  
work in Michigan. I'd like to say if we were going to do  
something, let's do it right. Let's start thinking of  
boxing as a business, come up with a plan. Maybe move it  
outside of the Department that it's in now and place it  
under Pure Michigan, entertainment, tourism, gaming,  
because right now we're literally handcuffing what could  
be one of the biggest industries we have in the State.  
On the subject of reliability of  
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officials and appearance of impropriety, I believe  
there's a need for training of officials on all levels,  
from new officials to championship officials. At the  
World Boxing Council, we have such a program, and I've  
been part of the developing -- in developing a  
university-level program for officials in Mexico City,  
and I would be glad to share that here with our officials  
at no cost. And in fact, we do have one official here  
from Grand Rapids who has been taking a part in one of  
these offshoot lessons that we have and training, and he  
recently was assigned his first world championship a  
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couple weeks ago.  
Our officials need to be protected.  
Since promoters were allowed to assign their own  
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officials, our officials have been locked out of fights  
that have taken place in our State by officials from New  
York, Canada, Indiana, and other places, fights that  
would have given these officials national recognition and  
experience. We once had a rule on the books that for  
every bout held in Michigan, the referee and at least one  
judge would be from Michigan. We need to get some of  
these rules back in.  
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From what I have stated, I'd like to  
recommend that this proposal not be filed. And in  
closing, I know this is strong, but I suggest that we  
shut down all unarmed combat competition in the State and  
that we form a private committee outside the Commission  
to rewrite the rules, to write a business plan, which may  
include an executive director above the Commission and  
outside the Commission, and then present this to the  
Commission for approval. With the Commission currently  
only meeting a few times a year, I don't see how they can  
accomplish putting together these rule changes and a  
business proposal on their own, and that's why I feel we  
need to do this outside the Commission. Thank you.  
MR. JONES: Thank you for your comments,  
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Mr. Garza.  
Up next we have Collin and Matee, they  
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wish to speak together.  
MR. ROGERS: My name is Collin Rogers,  
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I'm here with Matee Tongbua, he's from Thailand,  
five-time world champion muay thai fighter and stadium  
champion. We are both from Final Round Training  
Center --  
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COURT REPORTER: Excuse me. I guess you  
do have to speak this way because I'm losing you.  
MR. ROGERS: Want me to just start over?  
COURT REPORTER: No. We are both from --  
MR. ROGERS: We are both from Ann Arbor,  
Michigan, we train out of Final Round Training Center.  
We can be reached at mtdragonleg@gmail.com.  
We had a few comments and questions to  
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make on the proposed muay thai rule set in the State of  
Michigan. There are a few discrepancies between other  
stately rule sets that are proposed, I believe the rule  
set was modeled off of New Jersey's current muay thai  
rule set.  
Currently in Rule 339.246, Rule 246,  
there is not a subsection for mixed martial arts  
requiring shin guards or head gear, albeit amateur or  
professional; however, the new rule set proposed in  
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R 339.246b, Rule 246b(7), lists, "An amateur kickboxing  
and muay thai contestant must wear protective headgear  
and shin and inset protectors." Is this rule only  
present for muay thai and kickboxing, and does this have  
any play with the contestants' experience levels or  
agreed-upon protections for the bout?  
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Muay thai is also listed as a form of  
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boxing in which blows are delivered with the hand, any  
part of the leg below the hip, including the foot, and  
clinching. We are concerned that this does not allow  
elbows as it is a very common occurrence of a weapon that  
elbows be included in muay thai, albeit the art of eight  
limbs as they call it. Elbow pads could become an  
additional option that would be required equipment under  
R 339.246b, Rule 246b, as muay thai after all is the art  
of eight limbs.  
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I'm sorry, moving on here in what I have.  
We have in Rules 232b(i), shoving, throwing, or wrestling  
an opponent when pushing in a legal clinch is listed as a  
foul. Does this mean a contestant may not, if  
opportunity presents itself, shove an opponent out of the  
clinch and resume attacking?  
That carries on into the next foul that  
we question under the rule set, which is (u) in the muay  
thai rule set fouls, "Tripping or sweeping an opponent,"  
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being listed as a foul. In muay thai, especially in  
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Thailand, tripping and sweeping an opponent is very often  
performed and is a high-scoring technique utilized to  
show technical precision and timing over your opponent.  
We see no reason why these techniques should be listed as  
fouls under a muay thai rule set in Michigan if the  
wishes of the Commission are to display the true nature  
of such a beautiful martial art. We ask that more detail  
be proposed in the rule set for what may be performed in  
the clinch as far as sweeping, throwing, pushing, or  
anything like that.  
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Moving back to the requirements of the  
protective gear, we ask that a subsection be created for  
gloves per weight class. In the previous rule set, it  
just lists between 8- and 16-ounce gloves, but no  
specifics for each weight class, at least in the mixed  
martial arts or proposed muay thai rule set.  
We'd also like to see more information  
listed from the Commission on licensing of muay thai  
judging as it is a very unique rule set and sport. Matee  
has refereed and judged traditional bouts, and if any  
more information or consultation be needed, please feel  
free to contact him.  
We appreciate the work you're doing  
towards legalizing such an important cultural sport and  
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martial art that impacts so many in our beautiful State  
of Michigan. Please let us know if there's anything I or  
Matee can do to be of assistance as we know that it's in  
everyone's best interest that the sport be safe,  
regulated, and legalized, while also holding the vast  
respect and integrity that comes with the art of muay  
thai.  
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Is there anything you want to say?  
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MR. TONGBUA: You already said it.  
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MR. ROGERS: Yeah. Okay. Thank you for  
your time.  
MR. TONGBUA: Thank you.  
MR. JONES: Thank you very much for your  
comments.  
Are there anybody else that wish to speak  
at this time? (No response.)  
As a reminder, the public comment period  
will remain open until 11:59 p.m. on Thursday, January 6,  
2022. You can email additional comments to me at  
jonesm52@michigan.gov, or by mail to the Commission at  
P.O. Box 30018, Lansing, Michigan 48909.  
So I hereby declare this hearing closed.  
The current time is 1:44. Thank you for coming.  
(At 1:44 p.m., the public hearing concluded.)  
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C E R T I F I C A T E  
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I, Lori Anne Penn (CSR-1315), do hereby  
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certify that I reported in stenotype the proceedings had  
in the above-entitled matter, that being the Public  
Hearing regarding Administrative Rules for Unarmed  
Combat, Rule Set 2020-131 LR, Department of Licensing and  
Regulatory Affairs, Corporations, Securities and  
Commercial Licensing Bureau, Sun Conference Room, 2407  
North Grand River Avenue, Lansing, Michigan on Thursday,  
December 16, 2021; and do further certify that the  
foregoing transcript, consisting of pages 1-18,  
constitutes a true and correct transcript of my stenotype  
notes.  
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_____  
Lori
Penn Reporting, LLC  
lori.penn@yahoo.com  
December 20, 2021  
24 Dated: ______________________________  
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Penn Reporting, LLC - lori.penn@yahoo.com  
;