Contract analysis

I. Introduction and Identification of Counsel and Client This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company duly incorporated and existing 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 Delaware subsidiary, Aurelius Media Am

II. Identification of StreamNow Holdings, Inc. StreamNow Holdings, Inc. is a corporation organized and existing under the laws of the State of Delaware (Delaware Secretary of State File No. 7291843), with its principal place of business located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a direct-to-consumer "super-aggregator" streaming platform that bundles content from

III. The Copyrighted Works at Issue Aurelius is the sole and exclusive owner of the United States copyrights in at least two hundred seventeen (217) audiovisual works that StreamNow has reproduced, distributed, and publicly performed without authorization, license, or consent of any kind. These 217 titles comprise one hundred forty-two (142) feature films and seventy-five (75) television series, the latter totaling o

IV. The Unauthorized Conduct A. Nature of the Infringement StreamNow has, without Aurelius's authorization, license, consent, or any other form of permission, engaged in the following infringing conduct with respect to all 217 Aurelius-owned audiovisual works:

1. Reproduction. StreamNow has reproduced the 217 titles by ingesting digital copies of those works into StreamNow's content management systems, servers, and platform library, in violation of Aurelius's exclusive right of reproduction under 17 U.S.C. § 106(1).

2. Distribution. StreamNow has distributed the 217 titles by making them available for on-demand streaming to StreamNow's paying subscribers and ad-supported users, thereby distributing copies of the works to the public, in violation of Aurelius's exclusive right of distribution under 17 U.S.C. § 106(3).

3. Public Performance. StreamNow has publicly performed the 217 titles by transmitting them—via streaming technology over the Internet and through connected device applications—to StreamNow's user base, thereby publicly performing those works by means of a device or process, in violation of Aurelius's exclusive right of public performance under 17 U.S.C. § 106(4). Each of the foregoing acts constitutes a separate and

1. Brindoval Channel Networks, Inc., a Texas corporation headquartered in Dallas, Texas;

2. BrightLoop Media, LLC, a Florida limited liability company headquartered in Miami, Florida;

3. Velvet Stream Partners, LP, a Canadian limited partnership headquartered in Toronto, Ontario, Canada; and

4. Pacific Lantern Digital Pty Ltd, an Australian proprietary limited company headquartered in Sydney, New South Wales, Australia. Each of these sublicenses created additional, unauthorized channels of distribution and public performance for the Aurelius content, multiplying the scope of the infringement and the resulting harm to Aurelius. StreamNow's sublicensing of content that it had no right to sublicense demonst

V. StreamNow Has No Valid License — Rejection of the MDD Sublicense Defense A. Sandra Yee's November 3, 2025 Email Aurelius is aware that StreamNow may seek to assert a defense based on its purported sublicense from a third-party intermediary. Specifically, in an email dated November 3, 2025, Sandra Yee, StreamNow's Vice President of Content Acquisition, represented to Raj Anantharam, Aurelius's Senior Vice President

VI. Legal Basis for Aurelius's Claims A. Federal Copyright Infringement (17 U.S.C. §§ 106, 501) StreamNow has violated Aurelius's exclusive rights under 17 U.S.C. § 106, including the right of reproduction (§ 106(1)), the right of distribution (§ 106(3)), and the right of public performance (§ 106(4)), with respect to each of the 217 audiovisual works identified in Exhibit A. Each unauthorized reproduction, distribut

1. Failure to Conduct Reasonable Due Diligence. As described in Section V.D above, StreamNow failed to take any reasonable steps to verify MDD's authority to license the Aurelius catalog, despite StreamNow's sophistication and the magnitude of the transaction.

2. Ogilvie's Known Former Employment at Aurelius. Franklin Ogilvie's prior employment at Aurelius Media Americas, and the circumstances of his departure, should have raised obvious red flags for any reasonable content acquirer regarding the provenance and legitimacy of the content being offered through MDD. A basic inquiry into MDD's principals would have revealed Ogilvie's background and prompted further investigati

3. Scale of the Infringement. The infringement involves 217 individual titles—including major film franchises and award-winning television series—exploited over a period of approximately 22 months. This is not a case of incidental or de minimis use; it is a commercial-scale appropriation of a substantial portion of a major media company's content library.

4. StreamNow's Sophistication. StreamNow is a major content aggregation platform with significant financial and operational resources, staffed by experienced content acquisition professionals who are expected to understand and comply with copyright law and industry licensing practices.

5. Continued Exploitation After Notice. StreamNow continued to exploit the Aurelius content even after Aurelius raised concerns through Raj Anantharam's inquiry in late October and early November 2025, which prompted Sandra Yee's November 3, 2025 email. StreamNow's continued distribution of the content after being put on inquiry notice of the rights issues further demonstrates willfulness and reckless disregard. C. D

VII. Damages A. Revenue Attributable to Infringing Content Aurelius has retained CipherTrace Analytics, LLC, a nationally recognized digital forensics and data analytics firm, to conduct a forensic analysis of StreamNow's exploitation of the 217 Aurelius titles. Based on CipherTrace's analysis—which utilized available viewership data, platform analytics, pricing structures, and industry benchmarks—StreamNow has gener

VIII. Specific Demands In light of the foregoing, Aurelius Global Media Group PLC, through its counsel, hereby demands that StreamNow Holdings, Inc. take the following actions immediately: Demand 1: Immediate Cessation. StreamNow shall immediately cease and desist from all unauthorized reproduction, distribution, public performance, and any other exploitation of the 217 Aurelius-owned audiovisual works identified in

IX. Response Window and Consequences of Non-Compliance StreamNow is afforded thirty (30) calendar days from the date of this letter—that is, no later than April 13, 2026—to respond substantively to the demands set forth herein and to commence good-faith settlement negotiations with Aurelius and its counsel. If StreamNow fails to comply with the demands set forth in this letter, or fails to engage in meaningful settle

X. Reservation of Rights This letter is not intended to be, and shall not be construed as, a complete or exhaustive statement of all facts known to Aurelius, all claims available to Aurelius, or all remedies that Aurelius may seek. The facts and legal theories set forth herein are presented in summary form and are based on the information available to Aurelius and its counsel as of the date of this letter. Aurelius's

XI. Communications and Direction for Response All communications and responses regarding this matter should be directed exclusively to the undersigned: Marcus Delgado, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8217 Email: mdelgado@calderwoodharkness.com If StreamNow is or intends to be represented by outside counsel in this matter, we req

XII. Closing Aurelius strongly urges StreamNow to take this matter with the seriousness it warrants and to respond promptly and constructively to the demands set forth in this letter. The unauthorized exploitation of 217 copyrighted audiovisual works over a 22-month period represents a substantial and ongoing violation of Aurelius's rights, and the resulting damages are significant and growing. Aurelius's preference