Contract analysis

I. EXECUTIVE SUMMARY You have asked me to analyze whether the United States District Court for the Central District of California, Los Angeles Division, is the proper forum for Aurelius Global Media Group PLC's ("Aurelius") anticipated copyright infringement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie (collectively, "Defendants"). This memora

II. FACTUAL BACKGROUND RELEVANT TO JURISDICTION AND VENUE The following factual summary is drawn from client documents, internal investigation materials, the Lexington IP Services copyright registration search completed January 22, 2026, and the preliminary findings of the CipherTrace forensic analysis. This summary is limited to facts bearing on jurisdiction and venue; a comprehensive factual recitation will be incl

1. Federal Copyright Infringement (Direct): Violations of 17 U.S.C. §§ 106 and 501 against StreamNow for the unauthorized reproduction, distribution, and public performance of 217 audiovisual works owned by Aurelius, comprising 142 feature films and 75 television series (1,038 episodes).

2. Contributory Copyright Infringement: Against MDD and Ogilvie for knowingly inducing, causing, and materially contributing to StreamNow's direct infringement by furnishing StreamNow with unauthorized copies and purported licenses for the 217 works.

3. Inducement of Infringement: Against MDD and Ogilvie for actively inducing StreamNow's infringement through the creation and dissemination of the fraudulent Content Distribution Agreement and related licensing documentation.

4. Unfair Business Practices: A claim under California Business and Professions Code § 17200 against all Defendants for engaging in unlawful, unfair, and fraudulent business practices in connection with the unauthorized exploitation of Aurelius's copyrighted works.

5. Tortious Interference with Prospective Economic Advantage: A state-law claim against MDD and Ogilvie for interfering with Aurelius's prospective licensing relationships and revenue streams by flooding the market with unauthorized copies of Aurelius content at below-market rates. The period of infringement spans approximately April 1, 2024, through January 31, 2026 — a period of approximately 22 months. During this

III. SUBJECT MATTER JURISDICTION A. Federal Question Jurisdiction — 28 U.S.C. § 1338(a) The primary basis for subject matter jurisdiction in this action is 28 U.S.C. § 1338(a), which provides: "The district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents, plant range protection, copyrights and trademarks. No State court shall have jurisdiction over any

Section 1338(a) thus grants the federal district courts both original and exclusive jurisdiction over civil actions arising under the Copyright Act. Aurelius's primary claims in this action arise directly under the United States Copyright Act, specifically 17 U.S.C. §§ 106 and 501. Section 106 sets forth the exclusive rights of copyright owners, including the rights of reproduction, distribution, and public performan

Section 1367(a) provides: "[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution." The Supreme Court articulated the governing standar

IV. PERSONAL JURISDICTION The following analysis addresses whether the Central District of California may exercise personal jurisdiction over each of the three prospective defendants. Under California's long-arm statute, Cal. Code Civ. Proc. § 410.10, California courts may exercise jurisdiction "on any basis not inconsistent with the Constitution of this state or of the United States." This provision is coextensive w

1. General Jurisdiction StreamNow Holdings, Inc. is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. This address is located within the Central District of California, Los Angeles Division. Under the Supreme Court's decision in Daimler AG v. Bauman, 571 U.S. 117 (2014), a corporation is subject to general (all-purpose) jurisdiction in the forums where it is "essentially at home." F

2. Specific Jurisdiction (Alternative Basis) Even if general jurisdiction were somehow disputed — which it should not be — specific jurisdiction over StreamNow is clearly and independently established. The Ninth Circuit applies a three-part test for specific jurisdiction, as articulated in Axiom Foods, Inc. v. Acerchem International, Inc., 874 F.3d 1064, 1068 (9th Cir. 2017): (1) The non-resident defendant must purpo

1. General Jurisdiction MDD is a California limited liability company, formed under California law and assigned California Secretary of State File Number 202115729430. Its registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California, Los Angeles Division. For unincorporated entities such as LLCs, the analysis of where the entity is "at home" for

2. Specific Jurisdiction (Alternative) Even if general jurisdiction over MDD were somehow questioned, specific jurisdiction is easily established. All of MDD's relevant conduct — the purported licensing of Aurelius content to StreamNow, the negotiation and execution of the Content Distribution Agreement on March 15, 2024, and the ongoing receipt of sublicensing revenue from StreamNow — occurred in California. MDD pur

1. General Jurisdiction Franklin Ogilvie is an individual who is domiciled in the state of California, residing in or around Beverly Hills. Under the Supreme Court's decision in Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011), an individual is subject to general jurisdiction in his or her state of domicile. Ogilvie's California domicile subjects him to general jurisdiction in California cour

2. Specific Jurisdiction (Alternative) Ogilvie's relevant conduct provides an ample basis for specific jurisdiction as well. All of the acts giving rise to Aurelius's claims — the formation and management of MDD, the negotiation and execution of the Content Distribution Agreement with StreamNow, the unauthorized exploitation of Aurelius's intellectual property, and the receipt of licensing revenue — occurred in Calif

V. VENUE ANALYSIS A. Copyright-Specific Venue Statute — 28 U.S.C. § 1400(a) The venue analysis begins with the copyright-specific venue statute, 28 U.S.C. § 1400(a), which provides: "Civil actions, suits, or proceedings arising under any Act of Congress relating to copyrights or exclusive rights in mask works may be instituted in the district in which the defendant or his agent resides or may be found." For purposes

Section 1391(b)(1): Venue is proper in "a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located." All three defendants reside in California: StreamNow is headquartered in Los Angeles; MDD is registered in Beverly Hills; and Ogilvie is domiciled in Beverly Hills. Moreover, all three defendants reside specifically within the Central District of C

Section 1391(b)(2): Venue is proper in "a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated." The events giving rise to Aurelius's claims occurred overwhelmingly within the Central District of California. The infringing conduct — the ingestion, hosting, and streaming of Aurelius's

1. Brindoval Channel Networks, Inc. — Dallas, Texas

2. BrightLoop Media, LLC — Miami, Florida

3. Velvet Stream Partners, LP — Toronto, Ontario, Canada

4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia These entities are not proposed as defendants in the initial complaint. However, I note for completeness that if any of these entities are later joined as defendants, venue in the Central District of California would remain proper under 28 U.S.C. § 1391(b)(2), as a substantial part of the events giving rise to the claims occurred in this district

VI. POTENTIAL JURISDICTIONAL CHALLENGES AND COUNTERARGUMENTS While I do not anticipate any viable jurisdictional challenge from any defendant, I address below the most likely arguments that Defendants' counsel might raise and explain why each would fail. A. StreamNow's Potential Forum Non Conveniens Argument StreamNow might argue that the Central District of California is an inconvenient forum and that the case shoul

VII. RECOMMENDATIONS Based on the foregoing analysis, I recommend the following: A. Forum Selection Aurelius should file its copyright infringement action in the United States District Court for the Central District of California, Los Angeles Division. This forum provides the strongest jurisdictional basis, the most convenient venue for all parties, and the greatest strategic advantages for Aurelius. No other forum o

1. Federal Subject Matter Jurisdiction: Plead 28 U.S.C. § 1338(a) as the primary basis for subject matter jurisdiction, identifying the claims as arising under the United States Copyright Act, 17 U.S.C. §§ 106 and 501.

2. Supplemental Jurisdiction: Plead 28 U.S.C. § 1367 as the basis for jurisdiction over the California Business and Professions Code § 17200 unfair competition claim and the tortious interference with prospective economic advantage claim, alleging that these state-law claims arise from the same case or controversy as the federal copyright claims.

3. Diversity Jurisdiction (Alternative): If Aurelius is the sole named plaintiff, reference 28 U.S.C. § 1332(a)(2) as an alternative jurisdictional basis, alleging that the action is between a citizen of a foreign state (Aurelius, United Kingdom) and citizens of a State (StreamNow — Delaware/California; MDD — California; Ogilvie — California), and that the amount in controversy exceeds $75,000 exclusive of interest a

4. Venue: Allege venue under 28 U.S.C. § 1400(a) as the primary basis, and alternatively under 28 U.S.C. § 1391(b)(1) (all defendants reside in California and in the Central District) and § 1391(b)(2) (substantial part of the events occurred in the Central District).

5. Personal Jurisdiction: Allege personal jurisdiction over each defendant separately, citing both general jurisdiction (domicile, headquarters, or principal place of business in California) and specific jurisdiction (forum-related infringing conduct, purposeful direction of activities toward the forum, and the reasonableness of exercising jurisdiction). C. Service of Process Service of process should be effectuated

VIII. CONCLUSION The United States District Court for the Central District of California, Los Angeles Division, is the proper and optimal forum for Aurelius Global Media Group PLC's copyright infringement action against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie. Subject matter jurisdiction is firmly established under 28 U.S.C. § 1338(a), which grants federal courts original an

1. Draft Complaint — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al. (forthcoming; to be prepared upon approval of forum selection).

2. Chain-of-Title Memorandum — Matter No. 1017-00003 (forthcoming; will address copyright ownership, registration chain, and standing for each of the 217 titles at issue).

3. Copyright Registration Summary Report — Prepared by Lexington IP Services; search completed January 22, 2026 (confirms registration status of all 217 titles, including registration numbers, effective dates, and timeliness determinations for statutory damages eligibility).

4. CipherTrace Forensic Analysis Summary — (forthcoming; will address digital forensic findings regarding StreamNow's ingestion and distribution of Aurelius content, metadata analysis, and attribution of unauthorized access to MDD/Ogilvie).

5. Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum — (forthcoming; will address Copyright Act preemption analysis and viability of the § 17200 claim). Prepared by Omar Siddiqui, Associate. Please direct any questions or comments to the undersigned at osiddiqui@[firm].com or extension 4217.