Omar,
Hope the weekend is treating you well so far — apologies for the Saturday email, but I wanted to get these assignments to you while everything is fresh. I know you've had eyes on this matter since we opened it on February 12, so you should have some baseline context already.
**Quick Background & Timeline**
As you know, we formally opened the Aurelius Global Media Group PLC matter (Matter No. 1017-00003) on Wednesday. The client contact is Fiona Hartwell, General Counsel of Aurelius. Marcus Delgado is the responsible partner and Catherine Bloom is the billing partner. The litigation hold notice went out to Aurelius yesterday, and the $150,000 retainer has been received and deposited. The pre-suit phase is budgeted at $485,000, so we need to be disciplined and efficient with our research time across the board.
Marcus wants to deliver a comprehensive pre-suit assessment memorandum to Fiona Hartwell by approximately **March 7, 2026**. Everything I'm assigning you below feeds directly into that deliverable. I'm assigning you five initial research workstreams that will form the analytical foundation of that memo. Details and deadlines for each are below.
---
### ASSIGNMENT 1: Jurisdictional & Venue Analysis for C.D. Cal.
- **Priority:** High - **Deadline:** February 27, 2026 - **Deliverable:** Internal memorandum
**Scope:**
- **Federal subject matter jurisdiction** under 28 U.S.C. § 1338 for copyright claims — this should be straightforward, but we need it documented cleanly. - **Personal jurisdiction over StreamNow Holdings, Inc.** — Delaware corporation (File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010, with its principal place of business in Los Angeles. General and specific jurisdiction analysis. - **Personal jurisdiction over Meridian Digital Distributors, LLC ("MDD")** — California LLC (SOS File No. 202115729430), registered address at 8912 Burton Way, Suite 200, Beverly Hills, CA 90211. Should be straightforward given it's a California entity, but please confirm. - **Venue analysis under 28 U.S.C. § 1400(a)** — both defendants are located in the Central District of California; confirm this is the proper venue for copyright actions. - **Supplemental jurisdiction under 28 U.S.C. § 1367** for the anticipated state-law unfair competition claim under Cal. Bus. & Prof. Code § 17200 — address any discretionary factors a court might consider. - **Opposing counsel note:** StreamNow's outside counsel is Grantham Roth & Pearce LLP — specifically Victoria Langford (partner) and Brian Matsuda (associate), located at 555 South Flower Street, Suite 4200, Los Angeles. Please note this for service and logistics purposes in your memo.
---
### ASSIGNMENT 2: Statute of Limitations Research
- **Priority:** High - **Deadline:** February 26, 2026 - **Deliverable:** Internal memorandum
**Scope:**
- Analyze the **three-year statute of limitations under 17 U.S.C. § 507(b)** as applied to our facts. - **Accrual analysis** — the infringement period runs from approximately **April 1, 2024, through January 31, 2026** (roughly 22 months of continuous infringement). Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, first discovered the Aurelius titles on the StreamNow platform on **October 15, 2025**, and escalated to Fiona Hartwell on **October 22, 2025**. - Discuss the **discovery rule versus the injury rule** in light of the Supreme Court's decisions in *Petrella v. Metro-Goldwyn-Mayer, Inc.* and *Warner Chappell Music, Inc. v. Nealy*. Walk through how each framework applies to our timeline. - **Confirm that all claims are timely** — even the earliest infringement (April 2024) falls well within three years of a potential **June 2026 filing**. I want this nailed down definitively. - Address any **potential laches defense** StreamNow might raise, particularly given the roughly eight-month gap between Kowalski's discovery in October 2025 and a June 2026 filing. - Flag the **contingent complaint filing target of June 2026** and work backward from that date to confirm the limitations window.
---
### ASSIGNMENT 3: Franklin Ogilvie & MDD Background Research
- **Priority:** High - **Deadline:** February 22, 2026 - **Deliverable:** Internal research memorandum
This one is the earliest deadline because Marcus wants the Ogilvie/MDD picture filled in before we finalize the claim structure. Please cover the following:
**Scope:**
- **Ogilvie's employment history at Aurelius Media Americas, Inc.** (approximately 2017 through June 30, 2021). He was a mid-level licensing manager. Pull together what we know from the client file and supplement with public records. - Summarize the **internal investigation into his unauthorized access** to Aurelius's content management systems — the client file should have background on this. - His **separation agreement dated June 30, 2021** — it included a non-compete, non-solicitation, and an explicit prohibition on the use of any Aurelius intellectual property. We need to understand the precise scope of these covenants. - His **subsequent formation of Meridian Digital Distributors, LLC** in late 2021 — California LLC, SOS File No. 202115729430, sole member/manager, registered at 8912 Burton Way, Suite 200, Beverly Hills, CA 90211. Pull the SOS filings and any available formation documents. - The **purported Content Distribution Agreement between MDD and StreamNow**, allegedly executed on **March 15, 2024**, covering 350+ titles including the **217 Aurelius titles**. Document what we know about this agreement and its terms. - Confirm and document that **Aurelius's records show it never granted MDD any license, sublicense, or distribution authority** over any Aurelius-owned content. MDD is not and has never been an authorized distributor. This is a critical factual foundation. - **Sandra Yee's email of November 3, 2025** — Yee is StreamNow's VP of Content Acquisition. She sent an email claiming MDD as StreamNow's source of rights for the Aurelius titles. This was sent in response to an informal inquiry from Raj Anantharam (Aurelius SVP, Content Licensing & Distribution). Please pull a copy of this email from the client file and incorporate it into your analysis. - Identify **potential claims against Ogilvie/MDD**: breach of separation agreement, fraud, contributory copyright infringement, and inducement of infringement. Provide a preliminary assessment of the strength and elements of each. - Run **public records, other business filings, and litigation searches** for both Ogilvie and MDD — any prior suits, judgments, liens, other entities, etc.
---
### ASSIGNMENT 4: StreamNow Corporate Structure & Business Model Analysis
- **Priority:** Medium - **Deadline:** February 28, 2026 - **Deliverable:** Internal memorandum
**Scope:**
- **Corporate details:** StreamNow Holdings, Inc., Delaware corporation (File No. 7291843), HQ at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. Registered agent: Capitol Registered Agents, Inc., 1209 Orange Street, Wilmington, DE 19801. Founded 2019; privately held. - **Ownership structure:** Majority-owned by Pinnacle Ventures Fund III, LP (~62% of fully diluted equity following a $145 million Series C closed in June 2022). GP is Pinnacle Ventures Management III, LLC; managing partner Howard Cheng, located at 101 California Street, Suite 3500, San Francisco, CA 94111. Document this from public filings and press to the extent available. - **Key leadership:** Derek Calloway (CEO & Co-Founder), Priya Menon (COO & Co-Founder), Tobias Rennert (General Counsel), Sandra Yee (VP, Content Acquisition). - **Financial profile:** Estimated FY2025 revenue of approximately $312 million. Source and document this figure. - **Business model analysis** — this is the most important part of this memo. StreamNow operates as a "super-aggregator" platform, bundling content from multiple studios and independent distributors into a single subscription or ad-supported (AVOD) interface. It's available in 14 countries and sublicenses content bundles to third-party MVPD and FAST channel operators. - **Critical legal point:** StreamNow exercises editorial control over catalog selection, pricing tiers, and geographic availability. This is directly relevant to the **DMCA safe harbor analysis** and our argument that **§ 512 is inapplicable**. StreamNow actively curates, licenses (or purports to license), and monetizes the content — it is not a passive hosting service. Please build the factual record to support this distinction. - **CipherTrace Analytics engagement:** Note that we have engaged CipherTrace Analytics (Dr. Nathan Frey, 2700 Sand Hill Road, Suite 130, Menlo Park, CA 94025) for forensic analysis. Their findings will supplement your analysis with viewership data and revenue attribution for the Aurelius titles on the StreamNow platform. Estimated CipherTrace fee is $175,000. You don't need to coordinate with them — just note the engagement and leave placeholders for where their data will plug in.
---
### ASSIGNMENT 5: FAST Channel Sublicensee Identification
- **Priority:** Medium - **Deadline:** March 1, 2026 - **Deliverable:** Internal memorandum
**Scope:**
StreamNow sublicensed content bundles containing Aurelius titles to at least four third-party FAST channel operators. For each of the following, please identify the entity type, jurisdiction of formation/registration, key personnel (to the extent ascertainable from public records), and the nature and scope of their relationship with StreamNow:
1. **Brindoval Channel Networks, Inc.** — Dallas, TX 2. **BrightLoop Media, LLC** — Miami, FL 3. **Velvet Stream Partners, LP** — Toronto, ON, Canada 4. **Pacific Lantern Digital Pty Ltd** — Sydney, NSW, Australia
Additional analysis:
- Assess each sublicensee's **potential exposure for secondary copyright infringement** — vicarious and/or contributory liability. - Address **strategic considerations**: should we include any or all of them in the demand/takedown letters? Should they be named as defendants, or is it more effective to focus on StreamNow as the primary target and use the sublicensee exposure as leverage? - Note the **$6.5 million in sublicensing fees** StreamNow received from FAST channel operators for bundles containing Aurelius content — this figure is part of the **$38.6 million in total attributable revenue** we're building into the damages model. - **Flag international service considerations** for Velvet Stream (Canada) and Pacific Lantern (Australia) — Hague Convention applicability, any bilateral treaties, estimated timelines and costs for international service.
---
### GENERAL INSTRUCTIONS
A few housekeeping items that apply across all five assignments:
- **All memos** should be marked **"PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT"** at the top of every page. - Use **Matter No. 1017-00003** on all documents. - **Bill all time to 1017-00003.** Your rate is $725/hour. Please be mindful of the overall pre-suit budget of $485,000 — we have multiple workstreams and expert engagements drawing from the same pool. - **Copyright registration data:** Lexington IP Services (Marissa Chung, Director of Copyright Research, 1625 I Street NW, Suite 400, Washington, DC 20006) completed the copyright registration search on **January 22, 2026**. The results are in the matter file. Please cross-reference those results where relevant in your memos. Key numbers: **189 timely registrations** and **28 late registrations** out of the **217 total titles** (142 films and 75 TV series comprising 1,038 episodes). The timely vs. late registration distinction will be significant for statutory damages eligibility, so please flag that wherever it comes up. - **Hargrove Economic Consulting Group** (Dr. Elena Vasquez, 350 South Grand Avenue, Suite 2800, Los Angeles, CA 90071) has been retained for the preliminary damages model at an estimated cost of $95,000. I'll be coordinating with them directly — no action needed from you on that front.
**What I'm working on in parallel:**
- MDD–StreamNow agreement analysis - DMCA safe harbor memorandum (§ 512 inapplicability) - Willfulness analysis - Copyright infringement claim analysis under 17 U.S.C. §§ 106, 501
**Key dates to keep in mind:**
- **~March 7, 2026:** Target for the comprehensive pre-suit assessment memorandum to Fiona Hartwell. All of your component memos must be completed before then so we can synthesize everything. - **Mid-March 2026:** Marcus wants the demand letter to StreamNow (attn: Tobias Rennert, General Counsel) ready to go, with a 30-day response window. - **June 2026:** Contingent complaint filing date if pre-suit resolution efforts are unsuccessful. The draft complaint needs to be ready as a contingency.
---
Omar, I know this is a lot to absorb in one email. If you have any questions or run into any issues on any of these workstreams, please flag them early rather than late — I'd much rather adjust course now than deal with surprises at the memo stage. I'm available to meet **Monday morning** to walk through priorities and answer any questions. Just grab time on my calendar whenever works for you.
Thanks — looking forward to working on this one together.
Best,
**Wendy Schultz** Senior Associate, intellectual Property Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, CA 90067 T: (310) 555-4218 E: wschultz@calderwoodharkness.com