Seven months later on December 17, 1923, in one of his first sanctioned defenses of the title, Bernstein lost to Johnny Dundee at Madison Square Garden in a highly controversial split decision. BoxRec noted that several newspaper sources, including the prestigious "New York Times", believed the judges made the wrong decision in the bout. Author Ken Blady wrote that several of the judges may have been influenced to vote against Bernstein. Not all papers believed the fight was a runaway win for Bernstein, however. Although the "Milwaukee Journal" noted that Dundee finished strong in the bout, and agreed with the decision they also noted "the sentiment of the crowd, based on the fighters' round by round showing, was that Bernstein had won easily." Typical of the strong language of the many papers that disagreed with the decision was the "Milwaukee Sentinel", who wrote "By probably the worst decision in local boxing history, Johnny Dundee of Jersey City regained his Junior Lightweight championship from Jack Bernstein."