Contract analysis

I. Purpose and Legal Obligation Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG") and its wholly-owned subsidiary Aurelius Media Americas, Inc. ("AMA") in connection with potential copyright infringement claims against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie, among other potential parties yet to be identified. T

II. Background Summary To provide context for the scope of the preservation obligation, we summarize below the factual background giving rise to the anticipated litigation. Aurelius Global Media Group PLC is a United Kingdom–based media conglomerate that owns an extensive library of copyrighted audiovisual content. Aurelius's content library encompasses over 4,200 film and television titles, including some of the mos

III. Scope of Preservation Obligation The preservation obligation set forth in this notice is intentionally broad in order to ensure that all potentially relevant materials are captured and preserved. The scope of the hold is defined by reference to the persons and entities covered, the applicable time period, and the subject matter categories described below. A. Persons and Entities Covered This litigation hold appl

1. The 217 Works at Issue. All documents relating to the creation, production, acquisition, ownership, copyright registration, licensing, distribution, and exploitation of each of the 217 audiovisual titles identified in the enclosed List of 217 Titles Subject to Litigation Hold. This includes, without limitation, all documents specifically relating to the Meridian franchise (six feature films), the Iron Compass seri

2. Copyright Registrations. All U.S. Copyright Office registration certificates, applications, correspondence with the Copyright Office, recordation documents, and chain-of-title documentation for each of the 217 titles at issue. This includes the 189 titles for which timely copyright registrations were filed prior to the commencement of infringement, as well as the 28 titles for which registrations postdate the comm

3. StreamNow Holdings, Inc. All communications, correspondence, documents, agreements, memoranda, and ESI of any kind that relate to, reference, or mention StreamNow Holdings, Inc., or any of the following individuals in their capacity as StreamNow officers, employees, agents, or representatives: Derek Calloway (Chief Executive Officer), Priya Menon (Chief Operating Officer), Tobias Rennert (General Counsel), Sandra

4. Meridian Digital Distributors, LLC. All communications, documents, agreements, and ESI relating to or referencing Meridian Digital Distributors, LLC, including any purported license, sublicense, distribution agreement, content supply agreement, or other arrangement of any kind, whether executed or merely proposed, between MDD and any party. This also includes any documents reflecting Aurelius's or AMA's awareness

5. Franklin Ogilvie. All personnel records, employment agreements (including any offer letters, employment contracts, and amendments), the separation agreement dated June 30, 2021 (including all exhibits and attachments, specifically including the non-compete, non-solicitation, and intellectual property usage prohibitions contained therein), performance reviews, internal investigation files, disciplinary records, war

6. Authorized Licensing and Distribution. All existing and historical license agreements, distribution agreements, content supply agreements, output deals, and other agreements pursuant to which Aurelius has authorized the exploitation of any of the 217 titles at issue, regardless of the platform, territory, or medium. This includes comparable arm's-length license agreements for the same or similar titles that may be

7. Internal Investigation (2021). All documents relating to the internal investigation of Franklin Ogilvie's unauthorized access to and misuse of Aurelius's content management systems conducted in 2021, including without limitation investigation reports, memoranda, forensic analysis reports, interview notes, witness statements, email reviews, system access audits, and any communications with Bexley Marsh Solicitors L

8. Discovery of Infringement and Subsequent Investigation. All documents and communications from October 15, 2025, onward relating to Lena Kowalski's discovery of Aurelius titles on the StreamNow platform, the escalation of the matter to Fiona Hartwell on October 22, 2025, the commencement and progress of the internal investigation, any informal or formal communications with StreamNow (including the November 3, 2025,

9. Revenue and Financial Data. All financial records, revenue reports, royalty statements, sales reports, accounting records, internal financial projections, budgets, and financial analyses relating to revenue generated from the 217 titles at issue during the relevant period (January 1, 2016, through the present). This includes licensing revenue received by Aurelius from authorized distributors, viewership and audien

10. FAST Channel Operators. All documents, communications, and ESI relating to Brindoval Channel Networks, Inc. (Dallas, Texas), BrightLoop Media, LLC (Miami, Florida), Velvet Stream Partners, LP (Toronto, Ontario, Canada), and Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia), including any communications regarding the sublicensing of Aurelius content to or through these entities, any license agre

11. Insurance. All documents relating to the Fortbridge Specialty Insurance Company media liability and IP enforcement insurance policy (Policy No. FSI-ML-2024-07821), including the policy itself, all endorsements, riders, and amendments, all correspondence with Fortbridge Specialty Insurance Company, all correspondence with Calder & Whitfield Insurance Brokers Ltd. (Aurelius's insurance broker), and any claims, noti

IV. Types of Materials to Be Preserved The preservation obligation extends to all forms of documents and information, regardless of the medium, format, or location in which they are stored. The following categories provide guidance but are not intended to be exhaustive. When in doubt, preserve. A. Electronically Stored Information (ESI) ESI constitutes the largest and most critical category of potentially relevant ma

V. Prohibition on Destruction, Alteration, or Concealment Effective immediately upon receipt of this notice, Aurelius and AMA must suspend all routine document destruction, recycling, and deletion policies as they pertain to any documents or ESI within the scope of this litigation hold. This suspension applies to all document retention and destruction schedules, records management policies, clean-desk policies, and a

VI. IT Coordination The effective implementation of this litigation hold requires close coordination between Aurelius's and AMA's IT departments and outside counsel. Accordingly, the IT departments at Aurelius (London) and AMA (Los Angeles) should be directed to take the following actions immediately: (a) Identify and Preserve Backup Tapes and Archives. Identify all backup tapes, disaster recovery archives, and other

VII. Key Custodians — Immediate Notification Required The following individuals have been identified as key custodians who are likely to possess documents and ESI within the scope of this litigation hold. Each of these individuals must be notified of the hold immediately and must receive either a copy of this notice or a custodian-specific preservation instruction:

1. Fiona Hartwell — General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell is the recipient of this notice and bears primary responsibility for implementing the litigation hold across the entire Aurelius organization. Ms. Hartwell's own files, communications, and records relating to the StreamNow matter, the Ogilvie investigation, and content licensing are within the scope of the hold.

2. Lena Kowalski — Head of Digital Rights Enforcement, Aurelius Global Media Group PLC. Ms. Kowalski discovered the unauthorized streaming of Aurelius content on the StreamNow platform on October 15, 2025, and is a central witness in the anticipated litigation. All of her files, communications, monitoring reports, investigation notes, and related materials must be preserved.

3. Raj Anantharam — Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC. Mr. Anantharam is the business-side content lead responsible for licensing and distribution of Aurelius titles and is the recipient of the November 3, 2025, email from Sandra Yee at StreamNow. All of his files, communications, licensing records, and related materials must be preserved.

4. Sir Alistair Pemberton — Chief Executive Officer, Aurelius Global Media Group PLC. To the extent Sir Alistair possesses any communications, memoranda, board presentations, or other materials relating to the StreamNow infringement, the Ogilvie investigation, or the licensing and distribution of the 217 titles at issue, all such materials must be preserved.

5. Additional Custodians. Any current or former employees of Aurelius or AMA who had involvement in any of the following matters must also be identified and notified: (a) The internal investigation of Franklin Ogilvie in 2021; (b) Ogilvie's employment, supervision, management, or separation from AMA; (c) The licensing, distribution, or exploitation of any of the 217 titles at issue; or (d) The discovery, investigatio

6. Heads of Information Technology at Aurelius (London) and AMA (Los Angeles), who must implement the technical preservation measures described in Sections V and VI above. All custodians should receive a copy of this litigation hold notice or a custodian-specific preservation instruction tailored to their role. Each custodian must acknowledge receipt in writing by signing and returning the enclosed Custodian Acknowle

VIII. Acknowledgment and Compliance Fiona Hartwell, on behalf of Aurelius Global Media Group PLC and Aurelius Media Americas, Inc., is requested to acknowledge receipt of this litigation hold notice in writing (by email or letter addressed to Marcus Delgado at the Calderwood & Harkness Los Angeles office) within five (5) business days of the date of this notice — that is, no later than February 21, 2026. The acknowle

IX. Duration of Hold This litigation hold remains in effect until further written notice from Calderwood & Harkness LLP. No individual within Aurelius or AMA has the authority to release, modify, or narrow this hold without written authorization from Calderwood & Harkness. The hold will not be released until the matter described herein is fully and finally resolved, whether by settlement, final judgment (including ex

X. Consequences of Non-Compliance We wish to emphasize in the strongest possible terms the seriousness of the preservation obligations described in this notice. Failure to comply with this litigation hold may expose Aurelius and AMA to severe legal consequences, including but not limited to: • Court-imposed sanctions, including monetary penalties assessed against the company and, in appropriate cases, against individ

1. List of 217 Titles Subject to Litigation Hold — Copyright Registration Summary Report compiled from Lexington IP Services data, completed January 22, 2026. This report identifies each of the 217 audiovisual works by title, format (feature film or television series), number of episodes (where applicable), U.S. Copyright Office registration number, registration date, and registration status (timely or post-infringem

2. Custodian Acknowledgment Form — Template for each custodian to sign confirming receipt of this litigation hold notice (or a custodian-specific preservation instruction) and acknowledging their understanding of their preservation obligations. Completed forms should be returned to Fiona Hartwell and forwarded to Calderwood & Harkness LLP.