Contract analysis

1. My full name is Lena Kowalski. I am the Head of Digital Rights Enforcement at Aurelius Global Media Group PLC ("Aurelius" or "AGMG"). Aurelius is a public limited company incorporated in England and Wales under the Companies Act 2006, registered with Companies House under Registration Number 08724561, and headquartered at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Ex

2. In my role as Head of Digital Rights Enforcement, I am responsible for monitoring, detecting, and enforcing Aurelius's digital rights across all platforms and territories worldwide. I report directly to Fiona Hartwell, General Counsel of Aurelius. In addition, I work closely with Raj Anantharam, Senior Vice President of Content Licensing & Distribution, who oversees all of Aurelius's authorized content licensing a

3. Aurelius owns and controls a library of over 4,200 film and television titles. Content in Aurelius's library is produced and acquired through Aurelius and its wholly-owned subsidiaries, including Aurelius Media Americas, Inc. ("AMA"), a corporation organized under the laws of the State of Delaware, with principal offices located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as

4. This declaration concerns 217 specific audiovisual works owned by Aurelius that are at issue in this action (the "Works at Issue" or the "217 Works"). The 217 Works comprise 142 feature films and 75 television series, the latter totaling 1,038 individual episodes. The Works at Issue include titles from across Aurelius's library, including all six films in the Meridian franchise, all four seasons (forty-eight episo

5. On October 15, 2025, in the course of routine digital rights monitoring activities that I conduct and supervise on an ongoing basis, I personally discovered that a substantial number of Aurelius-owned film and television titles were available for streaming on the platform operated by StreamNow Holdings, Inc. ("StreamNow"). StreamNow is a corporation organized under the laws of the State of Delaware (Delaware Divis

6. On October 22, 2025, I escalated the matter to Fiona Hartwell, General Counsel of Aurelius, providing Ms. Hartwell with a detailed written memorandum summarizing my findings, including the number of titles identified, representative screenshots and metadata captures, and a preliminary assessment of the scope and duration of the unauthorized distribution. At Ms. Hartwell's direction, I commenced a formal internal i

7. Based on my thorough review of Aurelius's licensing records and content management systems, and after consultation with Mr. Anantharam and members of his licensing team, I can confirm the following: (a) Aurelius has never executed any license agreement, sublicense agreement, distribution agreement, or any other form of authorization with StreamNow Holdings, Inc. with respect to any Aurelius-owned content, includin

8. In connection with the internal investigation, Mr. Anantharam, at my request and with the approval of General Counsel, made an informal inquiry to StreamNow regarding the source of the Aurelius content appearing on its platform. On November 3, 2025, Sandra Yee, Vice President of Content Acquisition at StreamNow, responded to Mr. Anantharam via email. In her email, Ms. Yee claimed that StreamNow had obtained the Au

9. The sole member and manager of Meridian Digital Distributors, LLC is Franklin Ogilvie. Mr. Ogilvie was formerly employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately June 2017 to June 30, 2021. During his employment, Mr. Ogilvie was involved in various aspects of Aurelius's content licensing operations, including the preparation of license agreements, management of content d

10. The unauthorized availability of the 217 Aurelius titles on StreamNow's platform has been ongoing for approximately twenty-two months, from approximately April 1, 2024, through at least January 31, 2026, based on the analysis conducted by my team and confirmed through the forensic investigation performed by CipherTrace Analytics, LLC. During this entire period, the titles were made available for streaming to subs

11. Based on my understanding of the analysis conducted by CipherTrace Analytics, LLC, the digital forensics and analytics firm retained by counsel in connection with this matter, StreamNow generated an estimated $38.6 million in total revenue attributable to the 217 Aurelius titles during the approximately twenty-two-month infringement period. This estimated total revenue comprises the following components: (a) Subs

12. The unauthorized availability of Aurelius content on StreamNow's platform and the four FAST channel sublicensees has caused and continues to cause irreparable harm to Aurelius's licensing program in several significant and compounding ways: (a) Erosion of Licensing Value. Aurelius licenses its content to authorized streaming platforms and distributors through carefully negotiated, arm's-length agreements that ref

13. Beyond the direct economic harms to Aurelius's licensing program, the unauthorized distribution of Aurelius content on StreamNow's platform and through the downstream sublicensees has caused and continues to cause significant reputational harm to Aurelius. Aurelius's reputation as a premium content provider — both among consumers and within the media and entertainment industry — depends on its ability to control

14. As of the date of this declaration, I have confirmed through continued monitoring by my team that Aurelius titles remain available on StreamNow's platform. The infringement is ongoing and continues to cause harm to Aurelius with each passing day. Each additional day of unauthorized availability results in further viewership of Aurelius content on unauthorized channels, further displacement of viewership from auth

15. While Aurelius intends to pursue the full measure of its actual damages, statutory damages where applicable, and the disgorgement of StreamNow's profits attributable to the unauthorized exploitation of Aurelius content, monetary damages alone are insufficient to compensate Aurelius for the ongoing and compounding harms described above. The harm to Aurelius's licensing relationships, exclusivity commitments, brand

16. Aurelius invests significant resources in monitoring and enforcing its digital rights worldwide, and I oversee the dedicated team responsible for detecting unauthorized distribution of Aurelius content across digital platforms, websites, and services. Upon discovery of the StreamNow infringement, Aurelius acted promptly and diligently to investigate the matter and to pursue its legal rights. The following timelin

17. The following exhibits are attached to or referenced in this declaration in support of the factual assertions set forth herein: • Exhibit A: Representative screenshots of Aurelius titles appearing on StreamNow's platform, including title pages, promotional artwork, and metadata, captured during monitoring activities conducted by my team between October 15, 2025, and February 28, 2026. • Exhibit B: Complete list o