Contract analysis

I. Executive Summary Calderwood & Harkness LLP has been asked to analyze whether the Fortbridge Specialty Insurance Company media liability and intellectual property enforcement policy held by Aurelius Global Media Group PLC ("Aurelius" or the "Insured") provides coverage for the costs of prosecuting the copyright infringement enforcement action against StreamNow Holdings, Inc. ("StreamNow") and related parties. This

II. Background of the Underlying Dispute A. Aurelius Global Media Group PLC — Insured Party Aurelius Global Media Group PLC ("Aurelius") is a public limited company incorporated in England and Wales under Companies House Registration No. 08724561, with its registered and principal offices at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Exchange's Alternative Investment Ma

1. Brindoval Channel Networks, Inc., a Texas corporation based in Dallas, Texas;

2. BrightLoop Media, LLC, a Florida limited liability company based in Miami, Florida;

3. Velvet Stream Partners, LP, a Canadian limited partnership based in Toronto, Ontario, Canada; and

4. Pacific Lantern Digital Pty Ltd, an Australian proprietary limited company based in Sydney, New South Wales, Australia. Each of these entities is believed to have publicly performed Aurelius content without authorization through their respective FAST channel services, thereby constituting additional acts of infringement. The claims that Aurelius intends to assert arise primarily under the United States Copyright A

III. Policy Identification and Summary A. Policy Details The relevant insurance policy is identified as follows: Fortbridge Specialty Insurance Company is a Connecticut-domiciled insurer that specializes in media, entertainment, and technology liability coverages. Fortbridge is rated A (Excellent) by A.M. Best and maintains surplus lines authority in all 50 states. The policy was placed through Calder & Whitfield, wh

IV. Coverage Analysis A. Whether Affirmative Copyright Enforcement Falls Within the Insuring Agreement The threshold coverage question is whether Aurelius's affirmative enforcement of its copyrights against StreamNow, MDD, Ogilvie, and the four FAST channel sublicensees falls within the scope of the policy's insuring agreements. Based on our preliminary review, we conclude that it does, subject to the caveats and unc

1. Direct copyright infringement claims against StreamNow (17 U.S.C. §§ 106, 501). These claims are the core of the enforcement action and fall squarely within the policy's IP enforcement grant. StreamNow is alleged to have reproduced, distributed, and publicly performed 217 Aurelius-owned works without authorization. The enforcement of these claims constitutes the prototypical exercise of the insured's intellectual

2. Contributory and inducement copyright infringement claims against MDD and Ogilvie. These secondary liability theories are derivative of the direct infringement claims and arise from the same common scheme. To the extent the policy covers enforcement of the insured's intellectual property rights, the pursuit of contributory and inducement theories against the parties who facilitated the infringement should be cover

3. State law unfair competition claims under Cal. Bus. & Prof. Code § 17200. The § 17200 claims are supplemental to the copyright infringement claims and are based on the same underlying conduct — the unauthorized exploitation of Aurelius content. The policy should cover costs incurred in prosecuting these claims to the extent they are part of the same enforcement action and arise from the same set of facts. However,

4. Common law tortious interference claims. The tortious interference claims present the most attenuated connection to the IP enforcement grant, as they are based on interference with Aurelius's business relationships rather than directly on infringement of intellectual property rights. The insurer may argue that tortious interference claims are not "enforcement of intellectual property rights" within the meaning of

V. Notice Requirements A. Timing of Notice The policy's notice provisions are among the most critical elements of the coverage analysis. Failure to provide timely notice to the insurer can result in a partial or complete forfeiture of coverage rights, depending on the governing law and the specific policy language. Under Connecticut law, an insurer seeking to disclaim coverage based on late notice bears the burden of

1. A clear identification of the policy by number (FSI-ML-2024-07821) and the named insured (Aurelius Global Media Group PLC);

2. A detailed description of the claim, including the nature of the infringement, the identity of the infringers, the affected works, the infringement period, and the date of discovery;

3. Identification of all adverse parties: StreamNow Holdings, Inc.; Meridian Digital Distributors, LLC; Franklin Ogilvie; Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd;

4. A description of the estimated exposure, including the preliminary damages estimate ($41.3 million) and the estimated enforcement costs;

5. Identification of retained counsel (Calderwood & Harkness LLP) and retained experts (CipherTrace Analytics, LLC; Lexington IP Services; Hargrove Economic Consulting Group, LLC), with a request for pre-approval if required by the policy;

6. A description of the enforcement strategy, including the proposed filing of a copyright infringement action in the United States District Court for the Central District of California;

7. A request for confirmation of coverage and for the insurer to identify a claims adjuster or coverage counsel to manage the claim; and

8. A reservation of the insured's rights under the policy, including the right to assert additional bases for coverage as the facts develop. The notice should be addressed to Fortbridge's claims department at 280 Trumbull Street, Hartford, CT 06103, with copies sent to Calder & Whitfield Insurance Brokers Ltd. at 71 Fenchurch Street, London EC3M 4BS, United Kingdom, Attention: Aurelius Account Team. The notice should

VI. Coordination with UK Counsel Costs Aurelius engaged Bexley Marsh Solicitors LLP, located at 14 Bedford Row, London WC1R 4ED, on November 18, 2025, to provide a preliminary UK-side assessment of the infringement and to advise on enforcement strategy. Bexley Marsh is a well-regarded London firm with a strong media and entertainment practice, and its engagement was a reasonable and prudent step in the investigation

VII. Interaction with Aurelius's Other Insurance Programs As a publicly listed multinational media company, Aurelius maintains a comprehensive insurance program that includes multiple lines of coverage. Aurelius's auditors, Whitmore & Pryce LLP, located at 25 Old Broad Street, London EC2N 1HQ, are responsible for reviewing the company's insurance program in connection with the annual audit. We recommend that Fiona Ha

VIII. Budget and Coverage Adequacy Based on the cost estimates set forth in Section II.C above, the anticipated enforcement costs are as follows: If the enforcement action proceeds through filing of the complaint, discovery (including e-discovery and document review), expert depositions, dispositive motion practice, pretrial preparation, and trial, total costs will increase substantially. Based on our experience with

IX. Risks and Uncertainties While our preliminary analysis is favorable, several risks and uncertainties could affect the outcome of the coverage analysis:

1. Late notice risk. The approximately four-month gap between discovery of the infringement (October 15, 2025) and the anticipated tender of notice (March 1, 2026 at the latest) creates a risk that Fortbridge may assert late notice as a basis for disclaiming or limiting coverage. Although we believe the delay is defensible given the complexity of the claim and the reasonable investigation undertaken by Aurelius, the

2. Possible insurer challenge to the affirmative enforcement reading. Although the policy's IP enforcement endorsement appears to cover affirmative enforcement actions on its plain terms, Fortbridge may take a narrower reading of the policy language and argue that the endorsement is limited to certain categories of enforcement actions or that it requires satisfaction of additional conditions not apparent from the bin