Contract analysis

I. Introduction and Purpose I write in my capacity as the Responsible Partner on the above-referenced matter in the intellectual Property Practice Group of Calderwood & Harkness LLP. The purpose of this letter is to provide you and your colleagues at Aurelius Global Media Group PLC ("AGMG" or "Aurelius") with a comprehensive status report summarizing the results of the pre-suit investigation and legal analysis that o

II. Executive Summary Based on the results of our pre-suit investigation and legal analysis, we have reached the following conclusions: Claims. Aurelius has strong, well-supported claims for copyright infringement under 17 U.S.C. §§ 106 and 501 against StreamNow Holdings, Inc. ("StreamNow") for the unauthorized reproduction, distribution, and public performance of 217 Aurelius-owned audiovisual works, consisting of 1

III. Summary of Factual Investigation A. Copyright Registration Verification As an initial step in our investigation, we retained Lexington IP Services, Inc. ("Lexington"), a specialist copyright research firm led by Marissa Chung, Director of Copyright Research, to conduct a comprehensive search of the records of the U.S. Copyright Office with respect to all 217 audiovisual titles at issue. Lexington completed its s

1. Brindoval Channel Networks, Inc. — Dallas, Texas

2. BrightLoop Media, LLC — Miami, Florida

3. Velvet Stream Partners, LP — Toronto, Ontario, Canada

4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia These sublicensing arrangements expanded the distribution footprint of Aurelius content beyond StreamNow's own platform and generated additional revenue for StreamNow. The sublicensing is significant both because it magnifies the scope of the infringement and because it provides an independent basis for damages. Revenue Attribution. CipherTrace d

IV. Summary of Legal Analysis We have conducted a thorough legal analysis of the claims available to Aurelius, the anticipated defenses, and the relevant procedural considerations. Our analysis is set forth in several detailed memoranda, which are referenced in the enclosures list at the conclusion of this letter. The following is a summary of our principal conclusions. A. Copyright Infringement — 17 U.S.C. §§ 106 an

V. Assessment of Anticipated Defenses Based on our analysis of the facts and applicable law, we anticipate that StreamNow may raise the following defenses. We assess each as weak and unlikely to succeed: Sublicense Defense. StreamNow's primary defense will likely be that it acquired the Aurelius content through a valid sublicense from MDD. This defense fails at the threshold because MDD had no authority from Aurelius

VI. Insurance Coverage We have identified a potentially applicable insurance policy that may provide coverage for Aurelius's enforcement litigation costs. Aurelius maintains a media liability and intellectual property enforcement policy with Fortbridge Specialty Insurance Company, Policy No. FSI-ML-2024-07821. The policy provides coverage of $25 million per occurrence and $50 million in the aggregate. Catherine Bloom

VII. Recommended Next Steps Based on the foregoing investigation and analysis, Calderwood & Harkness recommends the following course of action: A. Formal Demand Letter Service — March 14, 2026 We recommend serving a formal cease-and-desist and pre-suit demand letter on StreamNow Holdings, Inc. on March 14, 2026. The letter will be addressed to Tobias Rennert, General Counsel of StreamNow, and will be served via certi

1. A demand for the immediate cessation of all unauthorized reproduction, distribution, and public performance of the 217 Aurelius-owned titles.

2. A demand for the complete removal of all Aurelius content from StreamNow's platform and from all sublicensed channels and third-party platforms to which StreamNow has sublicensed Aurelius content.

3. A demand for a full and complete accounting of all revenues derived from the unauthorized exploitation of Aurelius content, broken down by title, territory, revenue type (subscription, advertising, sublicensing), and time period.

4. A demand for payment of damages in the amount of $41.3 million (subject to adjustment based on the final accounting). The demand letter will specifically identify the infringed titles and franchises — including the Meridian franchise, the Iron Compass series, and the Thornfield catalog — and will assert that the infringement is willful. The letter will expressly reject the MDD sublicense as void and without author

1. Demand the immediate cessation of all purported licensing, sublicensing, or distribution of any Aurelius-owned content.

2. Demand the preservation of all documents and records relating to MDD's acquisition, handling, and licensing of Aurelius content, including all communications with StreamNow and any other parties.

3. Demand a full accounting of all revenues received by MDD in connection with the exploitation of Aurelius content.

4. Place Ogilvie on notice of Aurelius's claims for contributory copyright infringement, inducement, breach of the separation agreement, and fraud. C. Takedown Demands to FAST Channel Sublicensees Also on March 14, 2026, we will serve takedown demand letters on each of the four FAST channel operators identified by CipherTrace as recipients of sublicensed content bundles containing Aurelius titles:

1. Brindoval Channel Networks, Inc. — Dallas, Texas

2. BrightLoop Media, LLC — Miami, Florida

3. Velvet Stream Partners, LP — Toronto, Ontario, Canada

4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia Each letter will demand the removal of all Aurelius content from the FAST channel operator's platform within ten (10) business days and will require the preservation of all records relating to the acquisition and distribution of the content, including all agreements with StreamNow and all records of revenues derived from the Aurelius content. D.

2. Meridian Digital Distributors, LLC

3. Franklin Ogilvie (individually) The complaint will assert the following causes of action:

1. First Cause of Action: Copyright infringement under 17 U.S.C. §§ 106 and 501 (against StreamNow).

2. Second Cause of Action: Contributory copyright infringement (against MDD and Ogilvie).

3. Third Cause of Action: Inducement of infringement (against MDD and Ogilvie).

4. Fourth Cause of Action: Unfair business practices under Cal. Bus. & Prof. Code § 17200 (against StreamNow).

5. Fifth Cause of Action: Tortious interference with prospective economic advantage (against StreamNow). The relief sought will include: • Actual damages and the infringer's profits, in an amount to be proven at trial (estimated at $41.3 million); • In the alternative, statutory damages under 17 U.S.C. § 504(c) for the timely-registered works; • A permanent injunction prohibiting all defendants from further unauthori

VIII. Budget and Cost Update The following is a summary of the estimated costs for the pre-suit phase of this matter, covering the period through the service of the demand letter and initial settlement negotiations: A retainer in the amount of $150,000 was received on February 14, 2026, and has been applied against fees and costs incurred to date. The applicable hourly rates for the Calderwood & Harkness engagement t

IX. Conclusion and Request for Authorization Based on the comprehensive pre-suit investigation and legal analysis summarized in this letter, Calderwood & Harkness is confident that Aurelius holds strong, well-supported claims against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie for copyright infringement and related causes of action. The preliminary damages estimate of $41.3 mill

1. Copyright Registration Summary Report — Lexington IP Services, Inc. (January 22, 2026)

2. Chain-of-Title Memorandum — Calderwood & Harkness LLP (February 25, 2026)

3. Franklin Ogilvie Background Memorandum — Calderwood & Harkness LLP (February 22, 2026)

4. MDD–StreamNow Agreement Analysis Memorandum — Calderwood & Harkness LLP (March 2, 2026)

5. CipherTrace Forensic Analysis Summary — CipherTrace Analytics, LLC (March 5, 2026)

6. StreamNow Platform & Business Model Memorandum — Calderwood & Harkness LLP (February 28, 2026)

7. FAST Channel Sublicensee Identification Memorandum — Calderwood & Harkness LLP (March 1, 2026)

8. Infringement Timeline & Evidence Matrix — Calderwood & Harkness LLP

9. Pre-Suit Assessment Memorandum — Calderwood & Harkness LLP (March 7, 2026)

10. Copyright Infringement Claim Analysis — Calderwood & Harkness LLP (March 3, 2026)

11. DMCA Safe Harbor Non-Applicability Memorandum — Calderwood & Harkness LLP (March 4, 2026)

12. Willfulness Analysis Memorandum — Calderwood & Harkness LLP (March 4, 2026)

13. Damages Analysis Memorandum — Calderwood & Harkness LLP / Hargrove Economic Consulting Group, LLC (March 6, 2026)

14. Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum — Calderwood & Harkness LLP (March 5, 2026)

15. Jurisdictional & Venue Analysis Memorandum — Calderwood & Harkness LLP (February 27, 2026)

16. Statute of Limitations Analysis — Calderwood & Harkness LLP (February 26, 2026)

17. Insurance Coverage Analysis Memorandum — Calderwood & Harkness LLP (February 24, 2026) This letter and its contents are protected by the attorney-client privilege and the work product doctrine. This communication is intended solely for the use of the addressee and the individuals identified in the copy line. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this communi