Contract analysis

I. Introduction and Identification of Counsel This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company duly incorporated under the laws of England and Wales (Companies House Registration No. 08724561), with its principal offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom, and its wholly-owned United States subsidiary, Aurelius Media Americas, Inc. ("AMA"

II. Background — Aurelius Global Media Group PLC Aurelius Global Media Group PLC is a leading United Kingdom-headquartered public media and entertainment conglomerate. Aurelius's shares are admitted to trading on the AIM market of the London Stock Exchange under the ticker symbol AGLM. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately US$

III. Mr. Ogilvie's Prior Employment and Separation Agreement Our investigation has established that you, Franklin Ogilvie, were employed by Aurelius Media Americas, Inc. as a licensing manager from approximately 2017 through June 30, 2021. During the course of your employment, you occupied a mid-level position within AMA's content licensing division and had access to Aurelius's proprietary content management systems,

IV. Formation of MDD and the Unauthorized Content Distribution Agreement Our investigation has further established the following facts concerning the formation of MDD and the unauthorized licensing of Aurelius content. In late 2021, approximately five to six months after your separation from AMA, you formed Meridian Digital Distributors, LLC in the State of California (Secretary of State File No. 202115729430). In th

V. Scope and Consequences of the Infringement The unauthorized licensing of Aurelius content by MDD has caused — and, until it is halted, continues to cause — substantial and irreparable harm to Aurelius. As a direct result of MDD's purported licensing under the CDA, StreamNow ingested all 217 Aurelius-owned titles into its streaming platform and made them available for on-demand streaming to its subscribers across f

VI. Legal Claims Against MDD and Franklin Ogilvie Based on the foregoing facts, Aurelius asserts the following legal claims against MDD and against you, Franklin Ogilvie, individually. A. Contributory Copyright Infringement (17 U.S.C. §§ 106, 501) MDD and you, Mr. Ogilvie, are liable for contributory copyright infringement under the Copyright Act of 1976, 17 U.S.C. §§ 106 and 501. To establish contributory infringeme

VII. Copyright Registration Status Of the 217 Aurelius-owned titles at issue, one hundred eighty-nine (189) are protected by timely United States copyright registrations — that is, the registrations were obtained either within three (3) months of first publication of the respective works or prior to the commencement of the infringement at issue. Pursuant to 17 U.S.C. § 412, the timely registration of these works enti

VIII. Demands Based on the foregoing facts and legal claims, Aurelius hereby makes the following demands upon MDD and upon you, Franklin Ogilvie, individually. A. Immediate Cessation MDD and you, Mr. Ogilvie, must immediately cease and desist from all purported licensing, sublicensing, distribution, marketing, promotion, or other exploitation of any and all audiovisual content owned by Aurelius Global Media Group PLC

IX. Reservation of Rights and Litigation Warning This letter is issued without prejudice to any and all rights, claims, and remedies available to Aurelius Global Media Group PLC, Aurelius Media Americas, Inc., and their subsidiaries and affiliates under federal and state law, in equity, and under contract, all of which are expressly reserved in their entirety. Aurelius has authorized this firm to file suit against MD

X. Direction to Obtain Counsel Given the gravity of the legal claims set forth in this letter, the magnitude of Aurelius's claimed damages, and the strong likelihood of litigation if the demands herein are not satisfied, Aurelius strongly recommends that you, Mr. Ogilvie, and MDD promptly retain qualified legal counsel experienced in copyright law and complex commercial litigation to advise you with respect to this m

XI. No Waiver Nothing in this letter shall be deemed or construed as a waiver, relinquishment, or limitation of any right, claim, or remedy available to Aurelius, AMA, or any of their subsidiaries or affiliates, whether arising under federal or state statute, common law, equity, or contract. All such rights, claims, and remedies are expressly reserved in their entirety. Aurelius's investigation of the conduct of MDD