Contract analysis

I. Purpose and Scope This memorandum provides a comprehensive analysis of StreamNow Holdings, Inc.'s corporate structure, business model, platform operations, revenue streams, and content acquisition practices. It has been prepared in connection with the pre-suit copyright infringement assessment being conducted on behalf of our client, Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), against StreamNow Holding

II. Corporate Structure and Ownership A. Formation and Basic Corporate Information StreamNow Holdings, Inc. is a corporation organized and existing under the laws of the State of Delaware. The company was incorporated in 2019 and is registered with the Delaware Division of Corporations under File Number 7291843. A copy of StreamNow's corporate registry filing is attached hereto as Appendix A. StreamNow's registered a

III. Business Model Overview A. The "Super-Aggregator" Model StreamNow operates under what the industry characterizes as a streaming "super-aggregator" model. Under this model, StreamNow does not primarily function as a content production studio. Rather, its core value proposition is the aggregation of content from multiple studios, independent distributors, production companies, and other content providers into a si

IV. Revenue Analysis A. Total Company Revenue StreamNow's estimated total revenue for fiscal year 2025 is approximately $312 million. Because StreamNow is privately held and does not file public financial reports, this revenue figure is an estimate derived from available market intelligence, industry analyst reports, and the forensic analysis conducted by CipherTrace Analytics. While this figure has not been confirme

V. Content Acquisition Practices A. Content Sourcing Model StreamNow acquires content for its platform through distribution agreements with studios, independent producers, and intermediary distributors and aggregators. The content acquisition function is a core operational activity of the company, reflecting its super-aggregator business model. Unlike a production studio that creates its own content or a platform tha

VI. Sublicensing to Third-Party FAST Channel Operators A. Nature of Sublicensing Arrangements StreamNow's exploitation of the Aurelius content was not limited to direct distribution through its own platform. Beyond making the 217 Aurelius titles available to consumers on the StreamNow platform itself, StreamNow also sublicensed content bundles containing Aurelius titles to third-party Free Ad-Supported Streaming Tele

1. Brindoval Channel Networks, Inc. — A Texas corporation headquartered in Dallas, Texas. Brindoval operates a network of FAST channels distributed through major smart TV and connected device platforms in the United States. CipherTrace's analysis identified Aurelius titles within Brindoval's programming lineup during the infringement period, and publicly available data regarding StreamNow's content supply relationshi

2. BrightLoop Media, LLC — A Florida limited liability company headquartered in Miami, Florida. BrightLoop operates FAST channels with a focus on entertainment and lifestyle content, distributed primarily in the United States and Latin American markets. CipherTrace identified Aurelius content within BrightLoop's channel offerings.

3. Velvet Stream Partners, LP — An Ontario limited partnership based in Toronto, Ontario, Canada. Velvet Stream operates FAST channels distributed in Canada and select international markets. CipherTrace identified Aurelius titles within Velvet Stream's programming.

4. Pacific Lantern Digital Pty Ltd — A proprietary limited company incorporated in New South Wales, Australia, headquartered in Sydney. Pacific Lantern operates FAST channels distributed in Australia and the Asia-Pacific region. CipherTrace identified Aurelius content within Pacific Lantern's channel offerings. The total sublicensing fees received by StreamNow from these four operators for content bundles containing

VII. DMCA § 512 Safe Harbor Inapplicability A. Overview of DMCA § 512 Safe Harbor

Section 512 of the Digital Millennium Copyright Act, codified at 17 U.S.C. § 512, provides safe harbor protections for certain categories of online service providers against monetary liability for copyright infringement that occurs through the use of their systems and networks. The safe harbor was enacted as part of the DMCA in 1998 to balance the interests of copyright holders against the need to provide legal certa

1. Active Curation and Editorial Control StreamNow's business model is built on the active selection, acquisition, and curation of content. StreamNow does not passively host content uploaded by users; rather, it affirmatively selects which titles to include in its catalog through deliberate content acquisition and licensing decisions made by its content acquisition team under the direction of Sandra Yee. StreamNow ex

2. Affirmative Licensing and Monetization StreamNow's content acquisition model is based on affirmative licensing transactions, not user uploads. StreamNow entered into a purported Content Distribution Agreement with MDD, dated March 15, 2024, through which it acquired (or purported to acquire) distribution rights to a catalog of more than 350 titles, including the 217 Aurelius-owned titles at issue. This licensing t

3. Financial Benefit Directly Attributable to Infringing Material

Section 512(c)(1)(B) provides that the safe harbor is not available where the service provider "receive[s] a financial benefit directly attributable to the infringing activity, in a case in which the service provider has the right and ability to control such activity." Both elements of this disqualifying condition are met in StreamNow's case. Financial Benefit. StreamNow received $38.6 million in revenue directly att

4. Knowledge / Red Flags Even if StreamNow could otherwise satisfy the requirements of the § 512(c) safe harbor — which, for the reasons discussed above, it cannot — the knowledge requirements of § 512(c)(1)(A) would independently disqualify it. Constructive Knowledge (Red Flags). As discussed in Section V.C above, multiple red flags were present that should have alerted StreamNow to the possibility that MDD did not

VIII. Implications for Claims Against StreamNow A. Copyright Infringement Claims The analysis of StreamNow's business model, platform operations, content acquisition practices, and revenue streams set forth in this memorandum provides a strong foundation for direct copyright infringement claims under 17 U.S.C. §§ 106 and 501. StreamNow's active role in acquiring, curating, distributing, and monetizing the 217 Aureliu