Contract analysis

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

II. Nature of the Infringement and Brindoval's Involvement Through ongoing monitoring, forensic investigation, and industry intelligence, Aurelius has determined that Brindoval is currently distributing, reproducing, and/or publicly performing copyrighted audiovisual works owned exclusively by Aurelius through one or more FAST (Free Ad-Supported Streaming Television) channels that Brindoval operates, controls, or oth

III. Source of the Unauthorized Content — The StreamNow Sublicense Upon thorough investigation, Aurelius has established that Brindoval obtained the Aurelius content through a sublicense from StreamNow Holdings, Inc. ("StreamNow"), a corporation organized under the laws of the State of Delaware (Secretary of State File No. 7291843), with its principal offices at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, Calif

IV. Aurelius's Rights — Copyright Ownership and Registration Aurelius and/or AMA are the exclusive owners of all copyrights in the 217 audiovisual works at issue, including all exclusive rights of reproduction, distribution, public performance, and display under Section 106 of the Copyright Act, 17 U.S.C. § 106. Aurelius's copyright ownership encompasses all formats, media, and distribution platforms, including witho

V. Legal Basis — Copyright Infringement Brindoval's unauthorized reproduction, distribution, and/or public performance of the 217 Aurelius titles through its FAST channels constitutes infringement of Aurelius's exclusive rights under Sections 106 and 501 of the Copyright Act, 17 U.S.C. §§ 106 and 501. Each unauthorized reproduction, each unauthorized distribution, and each unauthorized public performance of each of t

VI. Demands In light of the foregoing, Aurelius hereby makes the following demands of Brindoval: A. Immediate Takedown Brindoval must immediately cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned content on any and all FAST channels, platforms, services, and distribution outlets operated, controlled, managed, or supplied by Brindoval, whether directly or throug

VII. Reservation of Rights Aurelius expressly reserves all rights and remedies available to it under federal and state law, in equity, and at common law, including but not limited to the following: (a) Claims for copyright infringement under 17 U.S.C. §§ 106 and 501; (b) Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), which, for the 189 timely-registered works alone,

VIII. Cooperation Invitation We wish to note that if Brindoval promptly and fully complies with each of the demands set forth in this letter, cooperates with Aurelius's ongoing investigation into the unauthorized distribution chain, and provides the requested accounting and document preservation in a timely and complete manner, Aurelius will take such cooperation into account in determining whether and to what extent

IX. Closing We request that all communications regarding this matter be directed exclusively to the undersigned at the contact information provided below. Please reference Matter No. 1017-00003 in all correspondence. Wendy Schultz, Senior Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200 Email: wschultz@calderwoodharkness.com We trust that