Contract analysis

1. This is an action for copyright infringement under 17 U.S.C. §§ 106 and 501 arising from the unauthorized reproduction, distribution, and public performance of 217 copyrighted audiovisual works (the "Works") owned by Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. This action also asserts claims for contributory copyright infringement, inducement of copyright infringement, unfair busin

2. Defendant StreamNow Holdings, Inc. operated a streaming media "super-aggregator" platform that ingested and exploited Plaintiffs' Works without authorization for a period of approximately twenty-two (22) months, from approximately April 1, 2024 through January 31, 2026. During this period, StreamNow made Plaintiffs' valuable copyrighted content available to its subscribers in fourteen countries, reproduced and sto

3. StreamNow purportedly obtained the right to exploit Plaintiffs' content through a sublicense from Defendant Meridian Digital Distributors, LLC, a sham intermediary entity operated by Defendant Franklin Ogilvie. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc. whose employment was terminated on June 30, 2021 following an internal investigation that revealed unauthorized access to Aur

4. The 217 Works that Defendants exploited without authorization include some of Aurelius's most commercially valuable and culturally significant properties. Among the Works at issue are: (a) the "Meridian" franchise, consisting of six feature films with combined global box office receipts of approximately $1.43 billion; (b) the "Iron Compass" series, Aurelius's highest-rated original dramatic series, encompassing fo

5. StreamNow generated an estimated $38.6 million in revenue directly attributable to the infringing Aurelius content during the twenty-two-month infringement period, comprising subscription revenue, advertising revenue from its ad-supported tier, and sublicensing fees received from FAST channel operators. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a cat

6. By this action, Plaintiffs seek actual damages, disgorgement of Defendants' profits attributable to the infringement, statutory damages in the alternative for the 189 timely-registered Works, a permanent injunction prohibiting Defendants from any further exploitation of Plaintiffs' content, impoundment and destruction of all infringing copies, reasonable attorneys' fees and costs, restitution and injunctive relief

II. THE PARTIES A. Plaintiffs.

7. Plaintiff Aurelius Global Media Group PLC ("Aurelius" or "AGMG") is a public limited company duly organized and existing under the laws of England and Wales, registered with Companies House under Registration Number 08724561. Aurelius maintains its corporate headquarters at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius's ordinary shares are listed and traded on the Alternative Investment Market ("AI

8. Aurelius is a major international media and entertainment conglomerate with operations spanning content production, acquisition, licensing, distribution, and theatrical exhibition across multiple continents. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). Aurelius owns and administers a co

9. Plaintiff Aurelius Media Americas, Inc. ("AMA") is a corporation duly organized and existing under the laws of the State of Delaware. AMA is a wholly-owned subsidiary of Aurelius Global Media Group PLC. AMA maintains its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA manages Aurelius's content licensing, distribution, and intellectual property enforcement op

10. Defendant StreamNow Holdings, Inc. ("StreamNow") is a corporation duly organized and existing under the laws of the State of Delaware, Delaware Division of Corporations File Number 7291843. StreamNow maintains its corporate headquarters and principal place of business at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow's registered agent in Delaware is Capitol Registered Agents, Inc.,

11. StreamNow operates a streaming media "super-aggregator" platform that bundles content from multiple studios, production companies, and independent distributors into a single subscription-based or advertising-supported interface. StreamNow's platform is available to consumers in fourteen countries, including the United States, Canada, Australia, and eleven additional territories. In addition to its direct-to-consu

12. StreamNow is privately held. Approximately sixty-two percent (62%) of StreamNow's fully diluted equity is owned by Pinnacle Ventures Fund III, LP, a venture capital fund whose general partner is Pinnacle Ventures Management III, LLC (managing partner: Howard Cheng), headquartered at 101 California Street, Suite 3500, San Francisco, California 94111. Pinnacle Ventures Fund III, LP invested $145 million in StreamNo

13. StreamNow's senior leadership includes Chief Executive Officer and Co-Founder Derek Calloway, Chief Operating Officer and Co-Founder Priya Menon, General Counsel Tobias Rennert, and Vice President of Content Acquisition Sandra Yee. On information and belief, StreamNow's outside litigation counsel is the firm of Grantham Roth & Pearce LLP, located at 555 South Flower Street, Suite 4200, Los Angeles, California 900

14. Defendant Meridian Digital Distributors, LLC ("MDD") is a limited liability company organized and existing under the laws of the State of California, California Secretary of State File Number 202115729430. MDD's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD was formed in late 2021 by Defendant Franklin Ogilvie. Ogilvie is MDD's sole member and manager. As of February 2026,

15. Defendant Franklin Ogilvie ("Ogilvie") is an individual residing in or around Los Angeles, California. Ogilvie is the sole member and manager of Meridian Digital Distributors, LLC. Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. Ogilvie's employment was terminated following an internal investigation that revealed unauthorized ac

III. JURISDICTION AND VENUE A. Subject Matter Jurisdiction

16. This Court has original subject matter jurisdiction over Plaintiffs' federal copyright infringement claims (Counts I, II, and III) pursuant to 28 U.S.C. § 1331 (federal question jurisdiction) and 28 U.S.C. § 1338(a) (jurisdiction over actions arising under the Copyright Act).

17. This Court has supplemental jurisdiction over Plaintiffs' state law claims (Counts IV and V) pursuant to 28 U.S.C. § 1367(a), because those claims are so related to the federal copyright claims within the original jurisdiction of this Court that they form part of the same case or controversy under Article III of the United States Constitution. Specifically, Plaintiffs' state law claims for unfair business practic

18. This Court has personal jurisdiction over Defendant StreamNow Holdings, Inc. because StreamNow is headquartered in and maintains its principal place of business in Los Angeles, California, which is within the Central District of California. StreamNow conducts continuous and systematic business operations within this District and within the State of California.

19. This Court has personal jurisdiction over Defendant Meridian Digital Distributors, LLC because MDD is a California limited liability company with its registered address in Beverly Hills, California, which is within the Central District of California. MDD was organized under the laws of the State of California and, on information and belief, conducts business within this District and within the State of California

20. This Court has personal jurisdiction over Defendant Franklin Ogilvie because Ogilvie resides in or around Los Angeles, California, which is within the Central District of California. Ogilvie conducted the acts giving rise to this action, including the formation of MDD, the negotiation and execution of the purported Content Distribution Agreement with StreamNow, and the delivery of infringing content to StreamNow,

21. Each Defendant has sufficient minimum contacts with the State of California and with this District such that the exercise of personal jurisdiction over each Defendant comports with due process and is consistent with the requirements of the California long-arm statute, Cal. Code Civ. Proc. § 410.10. C. Venue.

22. Venue is proper in this District under 28 U.S.C. § 1400(a), which provides that civil actions arising under the copyright laws may be instituted in the district in which the defendant or the defendant's agent resides or may be found. All Defendants reside in, are domiciled in, or have their principal places of business within the Central District of California.

23. Venue is also proper under 28 U.S.C. § 1391(b)(1) and (b)(2), as all Defendants reside in this judicial district, and a substantial part of the events or omissions giving rise to the claims asserted herein occurred within this District. Specifically, the negotiation and execution of the purported Content Distribution Agreement between MDD and StreamNow, the ingestion and streaming of the infringing content on Str

IV. FACTUAL ALLEGATIONS A. Aurelius and Its Copyrighted Works

24. Aurelius Global Media Group PLC is a leading international media and entertainment conglomerate headquartered in London, United Kingdom. With a storied history spanning multiple decades, Aurelius has built one of the most valuable and diverse content libraries in the entertainment industry, comprising over 4,200 film and television titles. The library includes globally recognized franchises, critically acclaimed

25. Among the most commercially valuable and culturally significant properties in the Aurelius library are the following, each of which is at issue in this action: (a) The "Meridian" Franchise: A series of six interconnected feature films in the science fiction and action-adventure genres, produced between 2011 and 2023, with combined worldwide theatrical box office receipts of approximately $1.43 billion. The Meridi

26. Aurelius, through its wholly-owned subsidiary Aurelius Media Americas, Inc., owns all right, title, and interest in and to the copyrights in the 217 audiovisual Works at issue in this action (collectively, the "Works"). The 217 Works comprise 142 feature films and 75 television series encompassing a total of 1,038 individual episodes.

27. Aurelius licenses its content to authorized streaming platforms, broadcast networks, theatrical exhibitors, and content distributors worldwide through carefully negotiated licensing agreements. These agreements are managed by Aurelius's Senior Vice President of Content Licensing and Distribution, Raj Anantharam, and its Head of Digital Rights Enforcement, Lena Kowalski, in coordination with AMA's licensing team.

28. Of the 217 Works at issue in this action, 189 Works have valid and timely United States copyright registrations. These 189 registrations were obtained within three months of the date of first publication of each respective Work, or prior to the commencement of Defendants' infringement, thereby satisfying the registration timing requirements for eligibility for statutory damages and attorneys' fees under 17 U.S.C.

29. The remaining 28 Works have valid United States copyright registrations that post-date the commencement of Defendants' infringement. These 28 registrations were obtained between May 2024 and October 2025. Although these registrations satisfy the jurisdictional prerequisite for suit under 17 U.S.C. § 411(a), the Works covered by these registrations are eligible only for an award of actual damages and infringer's p

30. All 217 copyright registrations were verified by Lexington IP Services, Inc. (Marissa Chung, Director of Copyright Research) through a comprehensive search of the records maintained by the United States Copyright Office. That search was completed on January 22, 2026 and confirmed the validity and currency of each registration.

31. A complete list of the 217 Works, together with their respective titles, types (feature film or television series), number of episodes (for television series), United States Copyright Registration numbers, registration dates, dates of first publication, registration status (timely or late), and registrant entity, is attached hereto as Exhibit A and incorporated herein by reference. C. Franklin Ogilvie and Meridia

32. Defendant Franklin Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. In that capacity, Ogilvie was responsible for assisting with the administration of content licensing agreements in the Americas region and had access to Aurelius's proprietary content management systems, including databases of title metadata, licensing terms, and

33. Ogilvie's employment at Aurelius Media Americas was terminated effective June 30, 2021 following an internal investigation conducted by AMA's Human Resources and Legal departments. The investigation revealed that Ogilvie had engaged in unauthorized access to Aurelius's content management systems, including accessing files, databases, and systems beyond the scope of his authorized role and responsibilities.

34. On June 30, 2021, in connection with the termination of his employment, Ogilvie executed a separation agreement with Aurelius Media Americas, Inc. The separation agreement contained, among other material provisions: (i) a non-compete clause prohibiting Ogilvie from engaging in competitive activities with Aurelius for a specified period following the termination of his employment; (ii) a non-solicitation clause pr

35. In late 2021, approximately five months after his departure from Aurelius, Ogilvie formed Meridian Digital Distributors, LLC as a California limited liability company (California Secretary of State File Number 202115729430). Ogilvie registered himself as the sole member and manager of MDD. The entity's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

36. Aurelius has never granted MDD any license, sublicense, distribution agreement, letter of authorization, or any other form of permission or authority to reproduce, distribute, publicly perform, sublicense, or otherwise exploit any Aurelius-owned content. MDD has never been an authorized distributor of Aurelius. No officer, director, employee, or agent of Aurelius or AMA has ever authorized MDD or Ogilvie to act o

37. Despite the foregoing, Ogilvie, acting through MDD, falsely represented to StreamNow — and, on information and belief, potentially to other entities — that MDD held valid distribution rights to Aurelius content. These representations were materially false and were made in violation of Ogilvie's separation agreement and in furtherance of a deliberate scheme to misappropriate and exploit Aurelius's valuable copyrig

38. On or about March 15, 2024, Meridian Digital Distributors, LLC and StreamNow Holdings, Inc. executed a purported "Content Distribution Agreement" (the "MDD–StreamNow Agreement"). On information and belief, the MDD–StreamNow Agreement purported to grant StreamNow certain rights to reproduce, distribute, and publicly perform a catalog of more than 350 titles, including the 217 Aurelius Works at issue in this action

39. Sandra Yee, StreamNow's Vice President of Content Acquisition, acknowledged in an email communication dated November 3, 2025 — sent in response to an inquiry from Raj Anantharam, Aurelius's Senior Vice President of Content Licensing and Distribution — that StreamNow obtained the Aurelius content through a sublicense from MDD. Yee's email stated, in substance, that StreamNow's rights to the Aurelius titles were de

40. MDD had no authority to grant StreamNow or any other party any rights in the Aurelius Works. The MDD–StreamNow Agreement is therefore void and of no legal effect as to any Aurelius content. MDD could not convey rights that it did not possess, and StreamNow acquired no valid rights to the Aurelius Works through the MDD–StreamNow Agreement.

41. StreamNow failed to conduct reasonable due diligence regarding MDD's purported authority to license the Aurelius Works. Had StreamNow undertaken even minimal due diligence — such as contacting Aurelius or AMA directly, reviewing publicly available information about MDD's sole member and his prior employment at Aurelius, or verifying the chain of title for a catalog of 217 titles from a major international studio

42. Beginning on or about April 1, 2024, StreamNow ingested the 217 Aurelius Works into its platform content library. The ingestion process involved receiving digital master files of the Works from MDD, encoding or transcoding the files into formats suitable for streaming delivery, and uploading the files to StreamNow's servers and content delivery networks.

43. From approximately April 1, 2024 through at least January 31, 2026 — a period of approximately twenty-two (22) months — StreamNow made the 217 Works available for streaming to its subscribers in the United States, Canada, Australia, and eleven additional international territories, for a total of fourteen countries.

44. StreamNow reproduced the Works within the meaning of 17 U.S.C. § 106(1) by making and storing multiple copies of the Works on its servers, content delivery networks, and associated storage infrastructure. Each reproduction was made without authorization from Plaintiffs.

45. StreamNow distributed the Works within the meaning of 17 U.S.C. § 106(3) by transmitting copies of the Works to end users via its streaming platform. Each such transmission constituted a distribution of the Works to the public without authorization from Plaintiffs.

46. StreamNow publicly performed the Works within the meaning of 17 U.S.C. § 106(4) by streaming the Works to its subscribers. Each streaming transmission constituted a public performance of the Works without authorization from Plaintiffs.

47. The unauthorized exploitation continued unabated for the full twenty-two-month period, during which time StreamNow's subscriber base accessed the Aurelius Works through both StreamNow's subscription tier and its ad-supported (AVOD) tier. StreamNow featured a number of the Aurelius titles prominently in its platform interface, including in curated recommendation carousels, editorial playlists, and algorithmic reco

48. StreamNow is not a passive hosting service or mere conduit for content. StreamNow exercises editorial control over its content catalog, including the selection of titles for inclusion on its platform, the curation and organization of content within its user interface, the establishment of pricing tiers and subscription models, and the determination of geographic availability for individual titles. StreamNow activ

49. In addition to exploiting the Aurelius Works through its own direct-to-consumer streaming platform, StreamNow sublicensed content bundles containing Aurelius titles to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators. On information and belief, these sublicensing arrangements were made pursuant to StreamNow's standard FAST channel distribution agreements, under which Str

50. The four FAST channel operators to which StreamNow sublicensed bundles containing Aurelius content are: (a) Brindoval Channel Networks, Inc., a company based in Dallas, Texas; (b) BrightLoop Media, LLC, a company based in Miami, Florida; (c) Velvet Stream Partners, LP, a company based in Toronto, Ontario, Canada; and (d) Pacific Lantern Digital Pty Ltd, a company based in Sydney, New South Wales, Australia.

51. Each of these FAST channel operators further reproduced, distributed, and publicly performed the Aurelius Works without Aurelius's authorization, extending the reach of the unauthorized exploitation beyond StreamNow's own platform to additional consumer-facing distribution channels. Aurelius never authorized StreamNow to sublicense its content to any third party, and StreamNow had no right to grant any sublicense

52. Plaintiffs retained CipherTrace Analytics, LLC ("CipherTrace"), a digital forensic analytics firm, to identify and quantify StreamNow's revenue attributable to the infringing Aurelius content. Dr. Nathan Frey served as the engagement lead for CipherTrace's analysis. CipherTrace's analysis drew upon publicly available data, industry benchmarking data, and preliminary information obtained through Plaintiffs' pre-fi

53. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a catalog of similar size, quality, and market appeal over a period of twenty-two months in the relevant territories, is estimated at $14.2 million. This estimate is based on Aurelius's existing licensing agreements with authorized platforms for comparable content catalogs, adjusted for the specific titles,

54. Plaintiffs also retained Hargrove Economic Consulting Group, LLC ("Hargrove"), to prepare a preliminary damages analysis. Dr. Elena Vasquez of Hargrove served as the lead consultant. Dr. Vasquez's analysis estimates net recoverable damages of $41.3 million, comprising Plaintiffs' actual damages (lost licensing revenue) plus StreamNow's infringer's profits, with appropriate apportionment to avoid double-counting i

55. In the alternative, for the 189 Works with timely copyright registrations, Plaintiffs are entitled to elect statutory damages in lieu of actual damages and profits. Under 17 U.S.C. § 504(c)(2), where infringement is committed willfully, the Court may award statutory damages of up to $150,000 per work infringed. For the 189 timely-registered Works, the potential aggregate statutory damages award is up to $28,350,0

56. On October 15, 2025, Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, discovered that numerous Aurelius titles were streaming on the StreamNow platform without authorization. Kowalski identified the presence of Aurelius-owned content during a routine content monitoring sweep of digital streaming platforms conducted as part of Aurelius's ongoing intellectual property enforcement program.