Contract analysis

I. Executive Summary The purpose of this memorandum is to recommend the settlement authority and negotiation parameters that we respectfully request Aurelius Global Media Group PLC ("Aurelius" or the "Company") authorize in connection with Aurelius's pre-suit demand and potential litigation against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie (collectively,

II. Summary of Claims and Legal Position A. Federal Copyright Infringement (17 U.S.C. §§ 106, 501) Aurelius holds all relevant United States copyrights in the 217 audiovisual works at issue, encompassing 142 feature films and 75 television series (1,038 episodes). The chain of title for each work has been confirmed through a comprehensive analysis conducted by Calderwood & Harkness and verified by a registration sear

1. Failure to Conduct Reasonable Due Diligence. StreamNow failed to take reasonable steps to verify MDD's authority to distribute Aurelius content. Standard industry practice for a content platform of StreamNow's size and sophistication requires direct confirmation of rights with the content owner or its authorized agent, verification of chain-of-title documentation, and independent review of distribution rights. Str

2. Franklin Ogilvie's Known Former Employment at Aurelius. Franklin Ogilvie, the principal of MDD, is a former employee of Aurelius Media Americas, Inc. (a wholly owned subsidiary of Aurelius). Ogilvie's employment history was known or should have been known to StreamNow, and this connection to Aurelius should have prompted heightened scrutiny of MDD's purported authority. Instead, it appears that StreamNow viewed Og

3. Scale and Duration of Infringement. The infringement encompasses 217 distinct audiovisual works exploited over a period of approximately 22 months. This is not a case of isolated or inadvertent use of a single work; it reflects a sustained, large-scale commercial exploitation of a substantial portion of a major studio's content library.

4. StreamNow's Sophistication. StreamNow is a sophisticated content platform with estimated fiscal year 2025 revenue of approximately $312 million. It employs in-house legal counsel, including General Counsel Tobias Rennert, and maintains a content acquisition team. It is not a startup unfamiliar with content licensing practices.

5. Continued Exploitation After Aurelius Raised Concerns. Aurelius's Vice President of Rights Management, Diana Carstairs, contacted StreamNow by email on September 18, 2025, alerting StreamNow to the presence of Aurelius content on its platform and requesting information regarding StreamNow's claimed rights. StreamNow's in-house counsel responded on October 2, 2025, asserting that StreamNow held valid rights through

III. Damages Analysis A. Actual Damages Plus Infringer's Profits (Primary Theory) Under 17 U.S.C. § 504(b), a copyright owner is entitled to recover its actual damages and any additional profits of the infringer that are attributable to the infringement and are not taken into account in computing actual damages. The burden of proving infringer's profits rests initially on the copyright owner, who must present proof o

IV. Recommended Settlement Parameters A. Opening Demand We recommend an opening demand of $41.3 million, consistent with Hargrove's preliminary net recoverable damages estimate. This figure is supported by the detailed forensic analysis conducted by CipherTrace Analytics (Dr. Nathan Frey) and the economic modeling performed by Hargrove Economic Consulting Group (Dr. Elena Vasquez). The rationale for anchoring the ope

V. Litigation Risk Factors Any recommendation regarding settlement authority must account for the risks and uncertainties inherent in litigation. We have identified the following risk factors, organized by whether they favor settlement or favor pressing for a higher recovery. A. Risks Favoring Settlement Collectibility and StreamNow's Financial Capacity. StreamNow is a privately held company with estimated fiscal yea

VI. Estimated Litigation Costs Through Trial A. Calderwood & Harkness Fee Estimates The following table sets forth our estimated fees for each major phase of the litigation, from the pre-suit phase through post-trial motions. These estimates are based on our experience in comparable copyright infringement matters of this scale and complexity, and assume standard discovery and motion practice timelines in the Central

VII. Reputational Considerations The decision whether to pursue settlement or proceed to public litigation involves significant reputational considerations for Aurelius, StreamNow, and the broader content distribution ecosystem. Aurelius's Public Profile. Aurelius Global Media Group PLC is a publicly listed company on the London Stock Exchange (AIM: AGLM), with American Depositary Receipts traded over-the-counter in

VIII. Negotiation Strategy and Process A. Demand Letter Service Calderwood & Harkness has prepared a formal cease-and-desist and pre-suit demand letter to StreamNow Holdings, Inc. The demand letter is targeted for service on March 14, 2026, and will be addressed to Tobias Rennert, General Counsel, StreamNow Holdings, Inc., 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. The letter will be sent by FedEx ov

IX. Recommended Board Action Based on the analysis and recommendations set forth in this memorandum, we respectfully request that Fiona Hartwell, General Counsel, and Sir Alistair Pemberton, Chief Executive Officer, authorize the following actions on behalf of Aurelius Global Media Group PLC:

1. Service of Demand Letter. Authorization to serve the formal cease-and-desist and pre-suit demand letter on StreamNow Holdings, Inc., MDD, Franklin Ogilvie, and the four FAST channel sublicensees on March 14, 2026, with an opening monetary demand of $41.3 million plus the non-monetary terms described in Section IV.C.

2. Settlement Authority. Authorization to negotiate and, if appropriate, execute a settlement agreement with StreamNow on behalf of Aurelius, with a negotiation floor of $25 million plus permanent injunctive relief, full content takedown, and all non-monetary terms described in Section IV.C. Any proposed settlement below $25 million or without adequate injunctive and non-monetary protections will be referred back to

3. Litigation Authorization. Authorization to file suit in the United States District Court for the Central District of California (Los Angeles Division) if settlement is not reached by June 2026, with estimated total litigation costs through trial of approximately $3.6 million to $5.0 million (inclusive of attorneys' fees and expert costs, and exclusive of the success fee).

4. Emergency Injunctive Relief. Authorization to seek emergency injunctive relief, including a temporary restraining order and preliminary injunction, contemporaneously with or shortly after the filing of the complaint, as circumstances require.

5. Continued Expert Engagement. Authorization for the continued engagement of CipherTrace