Nogueira was expected to face Tito Ortiz on 26 March 2011 at UFC Fight Night 24. However, Ortiz received a cut whilst training for his match with Nogueira and was forced to withdraw from the match. Ortiz was replaced by Phil Davis on short-notice, with just 6 weeks remaining until the fight. Nogueira lost via unanimous decision (30-27, 30-27, 30-27).
