"Ndou lost his IBF 140-pound title to Malignaggi last June. Pursuant to a clause in their fight contract, Malignaggi owed Ndou an immediate rematch. He allowed Malignaggi to make a mandatory defense of his title against Ngoudjo, but he refuses to wait any longer for what’s owed to him. If Malignaggi does not fight him next, Ndou will initiate a court battle to enforce the rematch clause."

Sounds to me like he really thinks the ref cost him the fight and he wants a rematch.