Contract analysis

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

II. Background — The Unauthorized Sublicensing Chain Our investigation has uncovered a multi-layered unauthorized sublicensing scheme through which Aurelius's copyrighted content has been misappropriated and distributed without authorization. The relevant parties and the chain of unauthorized distribution are set forth below. A. StreamNow Holdings, Inc. and the Infringing Platform StreamNow Holdings, Inc. ("StreamNow

1. Brindoval Channel Networks, Inc., located in Dallas, Texas;

2. BrightLoop Media, LLC, located in Miami, Florida; and

3. Velvet Stream Partners, LP, located in Toronto, Ontario, Canada. Pacific Lantern has been distributing Aurelius content through its FAST channels—making the works available to the public for streaming and viewing—without any authorization from, or license agreement with, Aurelius or any entity lawfully entitled to grant such authorization. Pacific Lantern has no direct, indirect, or derivative contractual relation

III. Aurelius's Copyrights in the Works at Issue Aurelius, directly and through its wholly-owned subsidiary Aurelius Media Americas, Inc., is the exclusive owner of all United States and international copyrights in each of the 217 audiovisual works that Pacific Lantern has been distributing without authorization. The works at issue span a diverse range of Aurelius's content library and include, without limitation, ti

IV. Legal Basis — Copyright Infringement Pacific Lantern's conduct constitutes copyright infringement under the United States Copyright Act, 17 U.S.C. §§ 101 et seq., and under applicable international copyright law. Specifically: Pacific Lantern's unauthorized public performance, distribution, and reproduction of the 217 Aurelius-owned audiovisual works violates the exclusive rights of copyright owners under 17 U.S.

V. Revenue and Damages Context The scale of the unauthorized exploitation at issue is substantial, and Aurelius has suffered—and continues to suffer—significant economic harm as a result. CipherTrace Analytics, LLC's forensic analysis attributes a total of approximately US$38.6 million in revenue to StreamNow's unauthorized exploitation of Aurelius content over the twenty-two-month infringement period (April 1, 2024

VI. Demands In light of the foregoing, Aurelius, through undersigned counsel, hereby makes the following demands upon Pacific Lantern Digital Pty Ltd: A. Immediate Cessation and Takedown Aurelius demands that Pacific Lantern immediately cease all reproduction, distribution, public performance, public display, digital transmission, and any other exploitation of each and every one of the 217 Aurelius-owned audiovisual

VII. Reservation of Rights Aurelius expressly reserves all rights and remedies available to it at law and in equity, whether under United States federal or state law, Australian law, or the laws of any other applicable jurisdiction, including but not limited to: (a) Claims for direct copyright infringement under 17 U.S.C. §§ 106 and 501; (b) Claims for contributory copyright infringement and/or vicarious copyright in

VIII. Consequences of Non-Compliance Pacific Lantern is hereby placed on notice that if it fails to comply with the demands set forth in this letter within the specified timeframes, Aurelius will pursue all available legal remedies without further notice or delay. Such remedies include, but are not limited to: • Filing suit against Pacific Lantern for copyright infringement in the United States District Court for the

IX. Contact and Response Instructions All responses, communications, and correspondence regarding this matter should be directed to: Wendy Schultz Senior Associate, intellectual Property Group Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 553-4837 Facsimile: (310) 553-4899 Email: wschultz@calderwoodharkness.com Please reference Matter No. 1017-00003 in a