Contract analysis

I. Executive Summary This memorandum presents a comprehensive chain-of-title analysis for the 217 audiovisual works that form the basis of the anticipated copyright infringement action to be brought by Aurelius Global Media Group PLC ("AGMG") and its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and

II. Scope and Methodology A. Scope of Review This analysis covers all 217 audiovisual titles identified in the Copyright Registration Summary Report prepared by the undersigned based on search results obtained from Lexington IP Services, Inc. The 217 titles are broken down as follows: 142 feature films and 75 television series comprising a total of 1,038 individual episodes. The complete list of titles, together with

1. U.S. Copyright Office Records. U.S. Copyright Office registration certificates and recordation documents for all 217 titles, as compiled and delivered by Lexington IP Services, Inc. (search completed January 22, 2026). These records include Certificates of Registration (Form PA), supplementary registrations, and all recorded assignments, transfers, and other documents pertaining to the 217 titles.

2. Corporate Formation and Governance Documents. Aurelius corporate records, including articles of incorporation and memoranda of association for AGMG, certificates of formation and bylaws for AMA and other subsidiaries, and corporate restructuring documents reflecting changes in the Aurelius corporate family over time.

3. Work-for-Hire and Employment Agreements. Work-for-hire agreements, employment agreements, and contributor agreements for original productions, including agreements with directors, writers, composers, and other key creative contributors.

4. Acquisition and Assignment Agreements. Acquisition agreements, assignment agreements, and purchase agreements for titles acquired from third-party producers, distributors, or predecessor entities. These include both individual title acquisitions and catalog-level acquisitions.

5. Corporate Transaction Documents. Corporate transaction documents reflecting mergers, acquisitions, and intra-group asset transfers within the Aurelius corporate family, including share purchase agreements, asset purchase agreements, merger instruments, bills of sale, and assignment instruments, together with all schedules of intellectual property transferred.

6. Internal Aurelius Records. Internal Aurelius content management system records and licensing databases, provided by and reviewed in consultation with Lena Kowalski, Head of Digital Rights Enforcement, and Raj Anantharam, SVP, Content Licensing & Distribution. These records include digital rights management logs, licensing deal records, and content distribution tracking data.

7. AMA-Specific Records. Records maintained by Aurelius Media Americas, Inc. relating to U.S.-specific copyright registrations and assignments, including correspondence with the U.S. Copyright Office and internal registration tracking databases.

8. Auditor Records. Auditor records reviewed as necessary from Whitmore & Pryce LLP, Aurelius's independent auditors (25 Old Broad Street, London EC2N 1HQ), to confirm asset classifications and valuations of acquired intellectual property catalogs reflected on Aurelius's balance sheet. C. Methodology For each of the 217 titles, we traced ownership from the point of creation and first fixation through to present-day o

III. Corporate Background — Aurelius Global Media Group PLC An understanding of the Aurelius corporate structure is essential to the chain-of-title analysis, as the copyright holdings at issue are distributed between AGMG as the ultimate parent and AMA as its U.S. operating subsidiary. This section provides the relevant corporate background for each entity and identifies the predecessor and affiliated entities releva

IV. Ownership Pathways — Analysis by Category This section presents our analysis of the chain of title for the 217 works, organized by the three ownership pathway categories described in Section II.C above. A. Category 1: Original Productions (Work-for-Hire) Category 1 constitutes the largest category of the 217 titles. These are works produced by AGMG or AMA as "works made for hire" under 17 U.S.C. § 101, in which c

1. Basis of Ownership For each Category 1 title, copyright ownership vests in AGMG or AMA as the employer or commissioning party under one or both of the following bases: (a) Employee Works. Where key creative contributors — including directors, writers, editors, and composers — were employees of AGMG or AMA at the time they created their contributions, those contributions are works made for hire under the first pron

2. Supporting Documentation The following categories of documentation support the work-for-hire analysis for Category 1 titles: • Employment Agreements. Written employment agreements with key creative contributors confirming their status as employees of AGMG or AMA and containing express work-for-hire provisions vesting copyright ownership in the employer. • Work-for-Hire Clauses in Production Contracts. Production a

3. Key Franchises The following key franchises are among the Category 1 original productions: "Meridian" Franchise (6 Feature Films). All six films in the "Meridian" franchise were produced by AGMG through its UK production division. The films were directed by three directors, all of whom were engaged under written work-for-hire agreements. The screenplays were written by writers engaged under similar agreements. U.S

4. Co-Productions. A subset of Category 1 titles were co-produced by AGMG with third-party production companies. In each case, assignment agreements transferring all co-producer interests to AGMG have been verified and are on file. The co-production agreements uniformly provided that AGMG would own all worldwide intellectual property rights in the completed work, with the co-producer receiving only a share of net pro

5. Work-for-Hire Integrity We have confirmed that all key creative contributors for Category 1 titles — including directors, writers, and composers — were engaged under written work-for-hire agreements or, where applicable, their contributions fall squarely within the statutory categories of 17 U.S.C. § 101 for specially ordered or commissioned works. In every instance, the agreements contain both a primary work-for-

1. Tracing Methodology Each corporate transaction chain was traced through the following documentation: (a) Transaction Agreements. Asset purchase agreements, share purchase agreements, or merger instruments governing the acquisition of the predecessor entity or its assets by AGMG. (b) intellectual Property Schedules. Schedules of intellectual property transferred as part of each transaction, listing specific titles

2. Verification. For each Category 2 title, we verified the complete chain of title from the original creator or producer through the predecessor entity and onward to AGMG or AMA. In every case, the chain is documented by written instruments, and the relevant assignments have been recorded with the U.S. Copyright Office. No breaks, gaps, or ambiguities have been identified in any acquisition chain. Where a predecesso

3. Specific Transactions The three principal corporate transactions through which Category 2 titles were acquired — the Albion Film Holdings Ltd. acquisition (2009), the Pinnacle Studios International, Inc. acquisition (2014), and the Crowngate Television Productions Ltd. merger (2017) — are summarized in Section III.C above. Relevant corporate transaction documents are indexed in Exhibit D. C. Category 3: Titles Acq

1. Documentation. Each Category 3 acquisition is documented by the following: (a) Copyright Assignment Agreements. Written copyright assignment agreements, signed by both the assignor and the assignee, transferring all right, title, and interest in the specified copyrights to AGMG or AMA. In most cases, these assignment agreements have been recorded with the U.S. Copyright Office pursuant to 17 U.S.C. § 205. (b) Due

2. Scope of Rights Transferred All Category 3 assignments are exclusive and worldwide in scope, encompassing all media now known or hereafter devised, including but not limited to theatrical exhibition, television broadcasting, home entertainment, digital streaming, electronic sell-through, and free ad-supported streaming television ("FAST") channels. The assignments transfer the full bundle of exclusive rights under

3. Termination Rights Analysis We have analyzed whether any termination rights under 17 U.S.C. §§ 203 or 304 are currently exercisable with respect to any Category 3 title. Section 203 permits authors (or their heirs) to terminate grants of copyright executed on or after January 1, 1978, during a five-year window beginning at the end of 35 years from the date of execution of the grant. Section 304 permits termination

4. Competing Claims No competing ownership claims have been identified for any Category 3 title. In every case, the seller's representations and warranties as to clear title have been verified against U.S. Copyright Office records, and no conflicting assignments, licenses, or encumbrances appear in the public record.

V. Copyright Registration Status — Cross-Reference with Lexington IP Services Report A. Overview As noted in Section II.B above, Lexington IP Services, Inc. conducted a comprehensive search of U.S. Copyright Office records on behalf of Aurelius in connection with this matter. The search was completed on January 22, 2026, and was conducted under the supervision of Marissa Chung, Director of Copyright Research, at Lexi

VI. Analysis of Specific Key Franchises Given their commercial significance and the magnitude of damages likely attributable to their unauthorized exploitation, we present here a more detailed analysis of three key franchises within the 217 titles. A. "Meridian" Franchise (6 Feature Films) The "Meridian" franchise comprises six feature films produced by AGMG through its UK production division between 2010 and 2023. T

VII. Absence of Grants to Meridian Digital Distributors, LLC or StreamNow Holdings, Inc. A critical element of the anticipated infringement action is establishing that neither MDD, StreamNow, nor any of their sublicensees had authorization from Aurelius to reproduce, distribute, or publicly perform any of the 217 titles. This section presents our analysis on that point. A. No License or Authorization to MDD Aurelius'

VIII. Standing Analysis Under 17 U.S.C. § 501(b), "[t]he legal or beneficial owner of an exclusive right under a copyright is entitled to institute an action for any infringement of that particular right committed while he or she is the owner of it." AGMG and AMA, as the registered copyright owners (or assignees with recorded assignments) of all 217 titles at issue, have standing to bring suit for infringement of the

IX. Potential Chain-of-Title Challenges and Defensive Analysis While we conclude that the chain of title for all 217 titles is complete and defensible, prudent pre-litigation analysis requires us to anticipate potential challenges that defendants may raise. This section identifies the most likely categories of challenge and assesses their merit. A. Work-for-Hire Challenges Potential Defense. Defendants may argue that

X. Conclusions and Recommendations Based on the comprehensive chain-of-title analysis set forth in this memorandum, we reach the following conclusions and recommendations:

1. Ownership Confirmed. AGMG and/or AMA hold all relevant U.S. copyrights in each of the 217 audiovisual works at issue. The chain of title is complete and unbroken for every title, whether ownership arises through original production under the work-for-hire doctrine, acquisition through corporate transactions, or acquisition from third-party producers and distributors.

2. No Gaps Identified. No gaps, deficiencies, ambiguities, or competing claims have been identified in the chain of title for any of the 217 works. Every link in the chain, from creation or first fixation through to present-day ownership by AGMG or AMA, is supported by documented written instruments.

3. Standing Established. AGMG and AMA have standing to assert claims for copyright infringement under 17 U.S.C. §§ 106 and 501 in the U.S. District Court for the Central District of California. The registration prerequisite under 17 U.S.C. § 411(a) is satisfied for all 217 titles.

4. Registration Status. Of the 217 titles, 189 have timely U.S. copyright registrations and are eligible for statutory damages under 17 U.S.C. § 504(c) and attorneys' fees under 17 U.S.C. § 505. The remaining 28 titles have registrations that post-date the commencement of infringement and are eligible for actual damages and infringer's profits under 17 U.S.C. § 504(b) only.

5. No Authority Granted. No license, sublicense, distribution agreement, or other authorization of any kind was ever granted by AGMG, AMA, or any authorized Aurelius representative to MDD, Franklin Ogilvie, StreamNow, or any of the four FAST channel sublicensees (Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; or Pacific Lantern Digital Pty Ltd). The purported MDD–StreamNow Conten

6. Recommendation. The chain-of-title analysis fully supports proceeding with the pre-suit demand to StreamNow, MDD, and Franklin Ogilvie and, if necessary, the filing of a complaint for copyright infringement in the U.S. District Court for the Central District of California. No additional curative measures — such as supplementary registrations, corrective assignments, or additional recordations — are required at thi

XI. Exhibits / Appendices (Referenced) The following exhibits are referenced in this memorandum and are maintained in the matter file. They are available for review and will be updated as necessary in connection with the preparation of the complaint and supporting declarations. Exhibit A: Complete list of all 217 titles, including the following information for each title: (i) title; (ii) type (feature film or televis