Contract analysis

From: Wendy Schultz <wschultz@calderwoodharkness.com> To: Omar Siddiqui <osiddiqui@calderwoodharkness.com> Date: Sun, 15 Feb 2026 09:17:00 -0000 Subject: Aurelius v. StreamNow — Research Assignments & Deadlines [1017-00003]

Hope the weekend is treating you well so far — apologies for the Saturday email, but I wanted to get these assignments to you while everything is fresh. I know you've had eyes on this matter since we opened it on February 12, so you should have some baseline context already.

As you know, we formally opened the Aurelius Global Media Group PLC matter (Matter No. 1017-00003) on Wednesday. The client contact is Fiona Hartwell, General Counsel of Aurelius. Marcus Delgado is the responsible partner and Catherine Bloom is the billing partner. The litigation hold notice went out to Aurelius yesterday, and the $150,000 retainer has been received and deposited. The pre-suit phase is budgeted at $4

Marcus wants to deliver a comprehensive pre-suit assessment memorandum to Fiona Hartwell by approximately **March 7, 2026**. Everything I'm assigning you below feeds directly into that deliverable. I'm assigning you five initial research workstreams that will form the analytical foundation of that memo. Details and deadlines for each are below.

### ASSIGNMENT 1: Jurisdictional & Venue Analysis for C.D. Cal.

- **Priority:** High - **Deadline:** February 27, 2026 - **Deliverable:** Internal memorandum

- **Federal subject matter jurisdiction** under 28 U.S.C. § 1338 for copyright claims — this should be straightforward, but we need it documented cleanly. - **Personal jurisdiction over StreamNow Holdings, Inc.** — Delaware corporation (File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010, with its principal place of business in Los Angeles. General and specific jurisdiction

### ASSIGNMENT 2: Statute of Limitations Research

- **Priority:** High - **Deadline:** February 26, 2026 - **Deliverable:** Internal memorandum

- Analyze the **three-year statute of limitations under 17 U.S.C. § 507(b)** as applied to our facts. - **Accrual analysis** — the infringement period runs from approximately **April 1, 2024, through January 31, 2026** (roughly 22 months of continuous infringement). Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, first discovered the Aurelius titles on the StreamNow platform on **October 15, 2025**, and

### ASSIGNMENT 3: Franklin Ogilvie & MDD Background Research

- **Priority:** High - **Deadline:** February 22, 2026 - **Deliverable:** Internal research memorandum

This one is the earliest deadline because Marcus wants the Ogilvie/MDD picture filled in before we finalize the claim structure. Please cover the following:

- **Ogilvie's employment history at Aurelius Media Americas, Inc.** (approximately 2017 through June 30, 2021). He was a mid-level licensing manager. Pull together what we know from the client file and supplement with public records. - Summarize the **internal investigation into his unauthorized access** to Aurelius's content management systems — the client file should have background on this. - His **separation agre

### ASSIGNMENT 4: StreamNow Corporate Structure & Business Model Analysis

- **Priority:** Medium - **Deadline:** February 28, 2026 - **Deliverable:** Internal memorandum

- **Corporate details:** StreamNow Holdings, Inc., Delaware corporation (File No. 7291843), HQ at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. Registered agent: Capitol Registered Agents, Inc., 1209 Orange Street, Wilmington, DE 19801. Founded 2019; privately held. - **Ownership structure:** Majority-owned by Pinnacle Ventures Fund III, LP (~62% of fully diluted equity following a $145 million Series C

### ASSIGNMENT 5: FAST Channel Sublicensee Identification

- **Priority:** Medium - **Deadline:** March 1, 2026 - **Deliverable:** Internal memorandum

StreamNow sublicensed content bundles containing Aurelius titles to at least four third-party FAST channel operators. For each of the following, please identify the entity type, jurisdiction of formation/registration, key personnel (to the extent ascertainable from public records), and the nature and scope of their relationship with StreamNow:

1. **Brindoval Channel Networks, Inc.** — Dallas, TX 2. **BrightLoop Media, LLC** — Miami, FL 3. **Velvet Stream Partners, LP** — Toronto, ON, Canada 4. **Pacific Lantern Digital Pty Ltd** — Sydney, NSW, Australia

- Assess each sublicensee's **potential exposure for secondary copyright infringement** — vicarious and/or contributory liability. - Address **strategic considerations**: should we include any or all of them in the demand/takedown letters? Should they be named as defendants, or is it more effective to focus on StreamNow as the primary target and use the sublicensee exposure as leverage? - Note the **$6.5 million in s

A few housekeeping items that apply across all five assignments:

- **All memos** should be marked **"PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT"** at the top of every page. - Use **Matter No. 1017-00003** on all documents. - **Bill all time to 1017-00003.** Your rate is $725/hour. Please be mindful of the overall pre-suit budget of $485,000 — we have multiple workstreams and expert engagements drawing from the same pool. - **Copyright registration data:** Lexington IP Ser

- MDD–StreamNow agreement analysis - DMCA safe harbor memorandum (§ 512 inapplicability) - Willfulness analysis - Copyright infringement claim analysis under 17 U.S.C. §§ 106, 501

- **~March 7, 2026:** Target for the comprehensive pre-suit assessment memorandum to Fiona Hartwell. All of your component memos must be completed before then so we can synthesize everything. - **Mid-March 2026:** Marcus wants the demand letter to StreamNow (attn: Tobias Rennert, General Counsel) ready to go, with a 30-day response window. - **June 2026:** Contingent complaint filing date if pre-suit resolution effor

Omar, I know this is a lot to absorb in one email. If you have any questions or run into any issues on any of these workstreams, please flag them early rather than late — I'd much rather adjust course now than deal with surprises at the memo stage. I'm available to meet **Monday morning** to walk through priorities and answer any questions. Just grab time on my calendar whenever works for you.

Thanks — looking forward to working on this one together.

**Wendy Schultz** Senior Associate, intellectual Property Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, CA 90067 T: (310) 555-4218 E: wschultz@calderwoodharkness.com