Contract analysis

I. BACKGROUND AND FACTUAL SUMMARY A. Aurelius's Content Ownership Aurelius and its subsidiaries hold all relevant United States copyrights in a catalog of at least 217 audiovisual works — comprising 142 feature films and 75 television series (encompassing 1,038 individual episodes) — that are the subject of this demand. Of these 217 works, 189 have been the subject of timely registrations with the United States Copyr

II. LEGAL BASIS A. Copyright Infringement Under 17 U.S.C. §§ 106 and 501 As the exclusive owner of the United States copyrights in the 217 audiovisual works at issue, Aurelius holds the exclusive rights set forth in Section 106 of the Copyright Act, 17 U.S.C. § 106, including without limitation: (1) The exclusive right to reproduce the copyrighted works in copies or phonorecords (17 U.S.C. § 106(1)); (3) The exclusiv

III. DEMANDS In light of the foregoing, Aurelius hereby makes the following demands: Demand 1: Immediate Cessation and Removal BrightLoop must immediately — meaning within twenty-four (24) hours of receipt of this letter — cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned audiovisual content across all of BrightLoop's FAST channels and any other platforms, serv

IV. RESERVATION OF RIGHTS Aurelius expressly reserves all of its rights, remedies, claims, and defenses, at law and in equity, including but not limited to the right to seek: (a) Actual damages and infringer's profits under 17 U.S.C. § 504(b); (b) Statutory damages, including enhanced statutory damages for willful infringement, under 17 U.S.C. § 504(c); (c) Temporary, preliminary, and permanent injunctive relief unde

V. PARALLEL ENFORCEMENT ACTIONS Please be advised that substantially similar takedown demands are being served simultaneously on the following parties: • StreamNow Holdings, Inc., via its General Counsel, Tobias Rennert, at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010; • Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager), at 8912 Burton Way, Suite 200, Beverly Hills, Cali

VI. INSTRUCTION TO SEEK LEGAL COUNSEL BrightLoop is strongly urged to consult immediately with its own legal counsel regarding its obligations under this letter, its potential liability for copyright infringement, and the potential consequences of non-compliance with the demands set forth herein. The issues presented in this letter are complex and carry significant financial and legal exposure for BrightLoop. BrightL

VII. CONCLUSION Aurelius demands that BrightLoop respond to and comply fully with each of the demands set forth in this letter within ten (10) business days of BrightLoop's receipt hereof. Aurelius intends to vigorously enforce its intellectual property rights and will not hesitate to pursue all available legal remedies — including the immediate commencement of federal litigation, emergency injunctive relief, and the