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Contract analysis / ciphertrace-forensic-summary.docx
ciphertrace-forensic-summary.docx
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I. PURPOSE AND SCOPE OF THIS SUMMARY
Medium
⚑ Assignment / subcontracting
I. PURPOSE AND SCOPE OF THIS SUMMARY This memorandum summarizes the technical and forensic findings of CipherTrace Analytics, LLC ("CipherTrace"), retained by Calderwood & Harkness LLP on behalf of Aurelius Global Media Group PLC ("Aurelius" or "AGMG") pursuant to the expert retention letter dated February 18, 2026. CipherTrace was engaged to perform a comprehensive digital forensic analysis of the StreamNow Holdings
II. CIPHERTRACE ANALYTICS — QUALIFICATIONS AND METHODOLOGY OVERVIEW
Standard
⚑ Commercial term
II. CIPHERTRACE ANALYTICS — QUALIFICATIONS AND METHODOLOGY OVERVIEW A. Firm Background and Expert Qualifications CipherTrace Analytics, LLC is a Delaware limited liability company headquartered at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. The firm specializes in digital media forensics, content identification and verification, and revenue attribution analysis for entertainment and technology-relat
III. CONTENT FINGERPRINTING RESULTS — CONFIRMATION OF INFRINGING TITLES
III. CONTENT FINGERPRINTING RESULTS — CONFIRMATION OF INFRINGING TITLES A. Overview of Findings CipherTrace's CT-AVF Engine v.4.2 confirmed the presence of all 217 Aurelius-owned audiovisual titles on the StreamNow platform during the Infringement Period. The confirmed titles consist of 142 feature films and 75 television series, with the television series comprising a total of 1,038 individual episodes. The fingerpr
IV. METADATA EXTRACTION — INGESTION DATES AND PLATFORM INTEGRATION
Medium
⚑ Assignment / subcontracting
IV. METADATA EXTRACTION — INGESTION DATES AND PLATFORM INTEGRATION A. Content Ingestion Timeline CipherTrace's extraction and analysis of StreamNow platform metadata reveals that the 217 Aurelius-owned audiovisual titles were ingested into the StreamNow platform content library beginning on or about April 1, 2024. The ingestion occurred in two distinct phases. The initial batch ingestion took place over approximately
V. VIEWERSHIP AND TRAFFIC DATA ANALYSIS
V. VIEWERSHIP AND TRAFFIC DATA ANALYSIS A. Aggregate Viewership Metrics CipherTrace's analysis of viewership and traffic data attributable to Aurelius titles on the StreamNow platform during the twenty-two-month Infringement Period reveals substantial and sustained audience engagement with the infringing content. Over the Infringement Period, Aurelius titles generated an estimated total of approximately 84.3 million
VI. REVENUE ATTRIBUTION ANALYSIS
Standard
⚑ Commercial term
VI. REVENUE ATTRIBUTION ANALYSIS A. Revenue Attribution Methodology CipherTrace developed a multi-factor revenue attribution model to quantify the economic value that StreamNow derived from the unauthorized exploitation of Aurelius content during the Infringement Period. The model was developed in consultation with Calderwood & Harkness LLP and with reference to preliminary data inputs and methodological guidance fro
1. Brindoval Channel Networks, Inc. — Dallas, Texas
1. Brindoval Channel Networks, Inc. — Dallas, Texas
2. BrightLoop Media, LLC — Miami, Florida
2. BrightLoop Media, LLC — Miami, Florida
3. Velvet Stream Partners, LP — Toronto, Ontario, Canada
3. Velvet Stream Partners, LP — Toronto, Ontario, Canada
4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia
Standard
⚑ Commercial term
4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia CipherTrace confirmed the presence of Aurelius titles within the sublicensed content bundles distributed to each of these operators through fingerprinting of the FAST channel content feeds using the CT-AVF Engine. The identification of Aurelius content on each sublicensee's FAST channel is documented in Exhibit F. Based on estimated sublicensing
VII. FAST CHANNEL SUBLICENSEE ANALYSIS
Standard
⚑ Commercial term
VII. FAST CHANNEL SUBLICENSEE ANALYSIS A. Identification of Sublicensees CipherTrace's forensic analysis extended beyond the StreamNow platform itself to identify and confirm the downstream distribution of Aurelius content through StreamNow's sublicensing relationships with third-party FAST channel operators. FAST channels are free, advertising-supported streaming television channels that distribute linear programmin
VIII. FINDINGS SUPPORTING ACTIVE CURATION AND DMCA NON-APPLICABILITY
VIII. FINDINGS SUPPORTING ACTIVE CURATION AND DMCA NON-APPLICABILITY CipherTrace's forensic analysis yields findings that are directly relevant to the legal determination of whether StreamNow may claim safe harbor protection under Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512. A threshold requirement for DMCA safe harbor eligibility is that the service provider function as a passive co
IX. ONGOING NATURE OF INFRINGEMENT
IX. ONGOING NATURE OF INFRINGEMENT As of CipherTrace's final data collection date of March 1, 2026, all 217 Aurelius-owned audiovisual titles remained available on the StreamNow platform. None of the titles had been removed, restricted, or made unavailable in any territory. Similarly, Aurelius content remained actively streaming on the four FAST channel sublicensee platforms operated by Brindoval Channel Networks, Br
X. KEY EXHIBITS AND SUPPORTING MATERIALS
Standard
⚑ Commercial term
X. KEY EXHIBITS AND SUPPORTING MATERIALS A. List of Exhibits Prepared by CipherTrace CipherTrace has prepared the following exhibits in connection with its forensic analysis, each of which is available for review by the engagement team and for inclusion in the pre-suit demand and anticipated litigation filings: Exhibit A: Complete list of all 217 Aurelius-owned audiovisual titles confirmed present on the StreamNow pl
XI. CONCLUSIONS
XI. CONCLUSIONS Based on the forensic analysis conducted by CipherTrace Analytics, LLC, the following principal conclusions are supported:
1. CipherTrace's content fingerprinting analysis confirms that all 217 Aurelius-owned aud
1. CipherTrace's content fingerprinting analysis confirms that all 217 Aurelius-owned audiovisual works — comprising 142 feature films and 75 television series encompassing 1,038 individual episodes — are present on the StreamNow platform and have been available for streaming since approximately April 1, 2024, a period of at least twenty-two months.
2. The content was ingested into the StreamNow platform shortly after the March 15, 2024
2. The content was ingested into the StreamNow platform shortly after the March 15, 2024 date of the purported Content Distribution Agreement between Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager; California Secretary of State File No. 202115729430; business address: 8912 Burton Way, Suite 200, Beverly Hills, California 90211) and StreamNow Holdings, Inc. (Delaware File No. 7291843; headqu
3. StreamNow actively curated, editorially promoted, and commercially monetized the Aurel
3. StreamNow actively curated, editorially promoted, and commercially monetized the Aurelius content across its subscription (SVOD), advertising-supported (AVOD), and sublicensing revenue channels, generating an estimated total of $38.6 million in attributable revenue during the Infringement Period.
4. The Aurelius content was distributed to viewers in all fourteen countries in which Str
4. The Aurelius content was distributed to viewers in all fourteen countries in which StreamNow operates and was sublicensed to four downstream FAST channel operators — Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd — without authorization from Aurelius.
5. StreamNow's active curation, editorial promotion, tier placement, geographic distribut
5. StreamNow's active curation, editorial promotion, tier placement, geographic distribution, and downstream sublicensing of the Aurelius content demonstrates that StreamNow functioned as a commercial content distributor, not a passive hosting service, and accordingly does not qualify for DMCA § 512 safe harbor protection.
6. The infringement is ongoing as of March 1, 2026, with all 217 titles remaining availab
6. The infringement is ongoing as of March 1, 2026, with all 217 titles remaining available on the StreamNow platform and on the four FAST channel sublicensee platforms.
7. These findings provide a strong technical and evidentiary foundation for the pre-suit
7. These findings provide a strong technical and evidentiary foundation for the pre-suit demand and anticipated litigation against StreamNow Holdings, Inc. and potentially against MDD, Franklin Ogilvie, and the FAST channel sublicensees, as may be determined by the engagement team in consultation with the client.
XII. PREPARATION AND DISTRIBUTION
Medium
⚑ Confidentiality undertaking
XII. PREPARATION AND DISTRIBUTION Prepared by: Omar Siddiqui, Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200 Email: osiddiqui@calderwoodharkness.com Reviewed by: Wendy Schultz, Senior Associate Calderwood & Harkness LLP Based on: CipherTrace Analytics, LLC preliminary findings report delivered to Calderwood & Harkness LLP on March 3, 20