On August 22, 1911, Papke had a surprising loss to Sailor Burke, at St. Nicholas Arena in New York City in a newspaper decision of the "New York Times". Papke was defending his World Middleweight title which he took at London's Palladium in a ninth round knockout from Jim Sullivan two months earlier on June 8, 1911. Burke battered Papke, but used little science in his approach. Attending the fight, and likely disappointed, was the Scottish reporter Percy Douglas, 10th Marquess of Queensberry, a member of the royal line and son of the 9th Marquess, who had endorsed the modern boxing rules published by Welshman John Graham Chambers in 1867. The title did not pass hands as both men were over the middleweight weight limit of 160, and weighing nearer 165.