1017-00003 · Aurelius Global Media Group · Demand & Correspondence

demand-letter-streamnow.docx DOCUMENT Litigation

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CALDERWOOD & HARKNESS LLP ATTORNEYS AT LAW

1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8200 Facsimile: (310) 556-8201 www.calderwoodharkness.com

March 14, 2026

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA EMAIL (trennert@streamnow.com)

Tobias Rennert, Esq. General Counsel StreamNow Holdings, Inc. 3400 Wilshire Boulevard, Suite 1800 Los Angeles, CA 90010

Re: Unauthorized Reproduction, Distribution, and Public Performance of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Cessation, Removal, Accounting, and Payment of Damages

Dear Mr. Rennert:

I. Introduction and Identification of Counsel and Client

This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company duly incorporated and existing under the laws of England and Wales (Companies House Registration No. 08724561), with its principal offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom, and its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. We are authorized to act on behalf of both Aurelius and AMA in connection with the matters set forth in this letter.

Aurelius is a publicly traded media and entertainment conglomerate whose ordinary shares are listed on the London Stock Exchange's AIM market under the ticker symbol AGLM, and whose American Depositary Receipts ("ADRs") are traded over-the-counter in the United States. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion), making it one of the leading independent media companies operating globally. Aurelius owns, controls, and exploits a content library comprising over 4,200 film and television titles across all media, formats, and territories worldwide.

Calderwood & Harkness LLP has been fully authorized by Aurelius and AMA to take all steps necessary and appropriate to protect Aurelius's intellectual property rights in connection with the infringing conduct described herein, including, without limitation, the commencement and prosecution of litigation in any court of competent jurisdiction.

The purpose of this letter is to formally demand that StreamNow Holdings, Inc. ("StreamNow" or "the Company") immediately cease and desist from all infringing activity involving Aurelius-owned copyrighted audiovisual works, and to set forth in detail the factual and legal basis for Aurelius's claims and the specific relief it requires. We urge you to treat this communication with the utmost seriousness.

II. Identification of StreamNow Holdings, Inc.

StreamNow Holdings, Inc. is a corporation organized and existing under the laws of the State of Delaware (Delaware Secretary of State File No. 7291843), with its principal place of business located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a direct-to-consumer "super-aggregator" streaming platform that bundles content from multiple studios, networks, and independent distributors into a single subscription-based or advertising-supported ("AVOD") interface. According to publicly available information and industry reporting, StreamNow's platform is currently available to consumers in fourteen (14) countries, including the United States, Canada, the United Kingdom, Australia, Germany, France, Brazil, Mexico, Japan, South Korea, India, Spain, Italy, and the Netherlands.

In addition to its direct-to-consumer operations, StreamNow sublicenses content bundles—including, as detailed below, Aurelius-owned content—to third-party multichannel video programming distributors ("MVPDs") and free ad-supported streaming television ("FAST") channel operators, thereby extending the reach and distribution of the content it purports to have licensed.

StreamNow is a privately held company. According to regulatory filings, industry reports, and information available through Bramwell Health IT and other data sources, majority ownership of StreamNow (approximately 62% of fully diluted equity) is held by Pinnacle Ventures Fund III, LP, a San Francisco-based growth equity fund that led StreamNow's $145 million Series C financing round in June 2022. StreamNow's estimated revenue for fiscal year 2025 is approximately $312 million, placing it among the largest independent streaming aggregation platforms in the United States. StreamNow is, by any measure, a sophisticated commercial enterprise with access to substantial financial, legal, and operational resources.

III. The Copyrighted Works at Issue

Aurelius is the sole and exclusive owner of the United States copyrights in at least two hundred seventeen (217) audiovisual works that StreamNow has reproduced, distributed, and publicly performed without authorization, license, or consent of any kind. These 217 titles comprise one hundred forty-two (142) feature films and seventy-five (75) television series, the latter totaling one thousand thirty-eight (1,038) individual episodes. The unauthorized exploitation of this catalog represents a massive and systematic appropriation of Aurelius's most valuable creative assets.

Among the works at issue are several of Aurelius's flagship franchises and marquee titles, including but not limited to:

• The "Meridian" Franchise: A series of six (6) interconnected feature films constituting one of Aurelius's most commercially successful film properties, with combined worldwide theatrical box office revenue of approximately $1.43 billion. The "Meridian" films are tentpole releases that anchor Aurelius's theatrical distribution strategy and generate significant downstream licensing, merchandising, and ancillary revenue.

• The "Iron Compass" Series: A four-season, forty-eight-episode (48-episode) original television series that is Aurelius's highest-rated original scripted program, drawing an average of 9.2 million UK viewers per episode during its initial broadcast run, with substantial viewership across multiple international territories.

• The "Thornfield" Period Drama Catalog: A collection of twelve (12) critically acclaimed period drama titles that have collectively won seven (7) British Academy of Film and Television Arts ("BAFTA") awards, representing a cornerstone of Aurelius's premium scripted content library and a perennial driver of international licensing revenue.

A complete schedule identifying each of the 217 titles at issue, together with corresponding United States Copyright Office registration numbers and other identifying information, is attached hereto as Exhibit A and incorporated herein by reference.

Copyright Registration Status. One hundred eighty-nine (189) of the 217 titles at issue have valid, timely United States copyright registrations—that is, registrations that were either made within three months of the work's first publication or made prior to the commencement of StreamNow's infringement. As a result, those 189 works are fully eligible for an award of statutory damages and reasonable attorneys' fees under 17 U.S.C. §§ 504(c) and 505. The remaining twenty-eight (28) titles have United States copyright registrations that, while valid, were obtained after the commencement of StreamNow's infringing conduct (registrations filed and issued between May 2024 and October 2025). Those 28 titles remain eligible for an award of actual damages and profits under 17 U.S.C. § 504(b).

The registration details for all 217 titles have been independently verified through a comprehensive search of the United States Copyright Office's public records, conducted by Lexington IP Services, Inc., a nationally recognized intellectual property search and due diligence firm, and completed on January 22, 2026. Aurelius's chain of title for each of the 217 works has been confirmed through review of chain-of-title documentation, assignment records, and corporate records, and is complete and unbroken in all respects.

IV. The Unauthorized Conduct

A. Nature of the Infringement

StreamNow has, without Aurelius's authorization, license, consent, or any other form of permission, engaged in the following infringing conduct with respect to all 217 Aurelius-owned audiovisual works:

1. Reproduction. StreamNow has reproduced the 217 titles by ingesting digital copies of those works into StreamNow's content management systems, servers, and platform library, in violation of Aurelius's exclusive right of reproduction under 17 U.S.C. § 106(1).

2. Distribution. StreamNow has distributed the 217 titles by making them available for on-demand streaming to StreamNow's paying subscribers and ad-supported users, thereby distributing copies of the works to the public, in violation of Aurelius's exclusive right of distribution under 17 U.S.C. § 106(3).

3. Public Performance. StreamNow has publicly performed the 217 titles by transmitting them—via streaming technology over the Internet and through connected device applications—to StreamNow's user base, thereby publicly performing those works by means of a device or process, in violation of Aurelius's exclusive right of public performance under 17 U.S.C. § 106(4).

Each of the foregoing acts constitutes a separate and independent violation of Aurelius's exclusive rights under the Copyright Act, 17 U.S.C. § 106. StreamNow's conduct is not the product of isolated or inadvertent error; rather, it reflects a sustained, commercial-scale exploitation of a massive catalog of copyrighted works over an extended period of time and across multiple territories.

B. Duration and Geographic Scope

Based on Aurelius's investigation to date, the infringement period spans approximately twenty-two (22) months, commencing on or about April 1, 2024, and continuing through at least January 31, 2026. Indeed, as of the date of this letter, Aurelius has reason to believe that the infringing activity is ongoing. Throughout this period, Aurelius content has been made available through the StreamNow platform to users in the United States, Canada, Australia, and at least eleven (11) additional territories in which StreamNow operates, encompassing a substantial portion of the global English-language streaming market as well as significant non-English-language markets.

The duration and scope of the infringement are significant. Over the course of nearly two years, StreamNow has derived commercial benefit from Aurelius's content on a continuous basis, embedding that content deeply into its platform's catalog, marketing materials, recommendation algorithms, and subscriber value proposition.

C. Sublicensing to FAST Channel Operators

StreamNow has materially compounded the infringement by sublicensing content bundles containing Aurelius-owned titles to at least four (4) third-party FAST channel operators, thereby extending the unauthorized reproduction, distribution, and public performance of Aurelius's copyrighted works far beyond StreamNow's own direct-to-consumer platform. The FAST channel operators to which StreamNow has sublicensed Aurelius content include:

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

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

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

4. Pacific Lantern Digital Pty Ltd, an Australian proprietary limited company headquartered in Sydney, New South Wales, Australia.

Each of these sublicenses created additional, unauthorized channels of distribution and public performance for the Aurelius content, multiplying the scope of the infringement and the resulting harm to Aurelius. StreamNow's sublicensing of content that it had no right to sublicense demonstrates a reckless disregard for the intellectual property rights of content owners and underscores the willful nature of StreamNow's conduct.

D. Discovery of the Infringement

Aurelius first discovered StreamNow's unauthorized exploitation of Aurelius content on October 15, 2025, when Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, identified multiple Aurelius-owned titles appearing on the StreamNow platform during a routine audit of unauthorized distribution channels. Ms. Kowalski immediately initiated an internal review and confirmed that the titles in question were being streamed through StreamNow without any corresponding license or authorization in Aurelius's rights management systems.

On October 22, 2025, the matter was escalated to Fiona Hartwell, Aurelius's General Counsel, and a formal internal investigation was commenced. The investigation rapidly confirmed that the scope of the unauthorized exploitation extended to at least 217 distinct titles across StreamNow's platform and sublicensed FAST channels.

In furtherance of its enforcement efforts, Aurelius retained UK counsel, Bexley Marsh Solicitors LLP, of London, England, who were formally engaged on November 18, 2025, to investigate and advise on the international aspects of the matter. Aurelius subsequently retained this firm, Calderwood & Harkness LLP, as its United States counsel, with the engagement formally opened on February 12, 2026, under Matter No. 1017-00003, to investigate and pursue all available claims in the United States.

V. StreamNow Has No Valid License — Rejection of the MDD Sublicense Defense

A. Sandra Yee's November 3, 2025 Email

Aurelius is aware that StreamNow may seek to assert a defense based on its purported sublicense from a third-party intermediary. Specifically, in an email dated November 3, 2025, Sandra Yee, StreamNow's Vice President of Content Acquisition, represented to Raj Anantharam, Aurelius's Senior Vice President of Content Licensing & Distribution, that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC ("MDD"), a Los Angeles-based content aggregator. In that email, Ms. Yee referenced a "Content Distribution Agreement" between MDD and StreamNow that was allegedly executed on March 15, 2024, and which purportedly covered over 350 titles, including the 217 Aurelius-owned titles at issue in this matter.

This purported defense is wholly without merit, for the reasons set forth below.

B. MDD Is Not and Has Never Been an Authorized Distributor

Meridian Digital Distributors, LLC (California Secretary of State File No. 202115729430) is a California limited liability company whose sole member and manager is Franklin Ogilvie. MDD was incorporated in late 2021, shortly after Mr. Ogilvie's departure from Aurelius Media Americas, Inc. under the circumstances described in Section V.C below.

Aurelius states, unequivocally and categorically, that:

• Aurelius has never granted MDD any license, sublicense, distribution authority, or any other form of authorization, whether written or oral, express or implied, over any Aurelius-owned content whatsoever.

• MDD is not and has never been an authorized distributor, agent, representative, sublicensee, or affiliate of Aurelius in any capacity.

• Aurelius has no contractual, commercial, or business relationship of any kind with MDD.

• Any purported "Content Distribution Agreement" between MDD and StreamNow, to the extent it purports to convey rights in Aurelius-owned content, is void and of no legal effect as to Aurelius's copyrights. One cannot convey rights one does not possess; nemo dat quod non habet.

C. Franklin Ogilvie's Background and Separation Agreement

Franklin Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 until June 30, 2021. During his tenure, Mr. Ogilvie was involved in certain aspects of Aurelius's content licensing operations in the Americas, but he held no authority to negotiate, execute, or grant licenses independently, and his role was subject to multiple levels of managerial approval and oversight.

Mr. Ogilvie's employment with Aurelius Media Americas was terminated effective June 30, 2021, following an internal investigation that revealed unauthorized access to Aurelius's proprietary content management systems and the downloading of confidential rights management data. The circumstances of Mr. Ogilvie's departure are directly relevant to the instant matter, as they establish that Mr. Ogilvie was known to have engaged in conduct inconsistent with the proper handling of Aurelius's intellectual property even before he founded MDD.

On June 30, 2021, in connection with his separation from Aurelius Media Americas, Mr. Ogilvie executed a separation agreement and general release (the "Separation Agreement") that included, among other provisions:

(a) A covenant not to compete with Aurelius or any of its subsidiaries or affiliates in the content licensing and distribution business for a period of two (2) years following his separation;

(b) A covenant not to solicit Aurelius's employees, clients, licensees, or business partners;

(c) An explicit and unambiguous prohibition on the use, disclosure, or exploitation of any Aurelius intellectual property, trade secrets, confidential information, or proprietary data; and

(d) A comprehensive release of any claims Mr. Ogilvie might have had to any rights in or to Aurelius content.

Mr. Ogilvie had no authority, at any time during or after his employment, to license, sublicense, distribute, or otherwise exploit Aurelius content, whether through MDD or any other entity. Any representations made by Mr. Ogilvie or MDD to StreamNow regarding rights to Aurelius content were false, unauthorized, and made without any basis whatsoever.

D. StreamNow's Due Diligence Failures

StreamNow is a sophisticated content aggregation platform with estimated annual revenues of $312 million, backed by a $145 million investment from a major growth equity fund, and operating across fourteen countries. As such, StreamNow is—and at all relevant times was—fully aware of the critical importance of verifying rights ownership and chain of title before acquiring and distributing copyrighted content. The content licensing industry has well-established norms and practices for conducting rights verification, including direct confirmation with the rights holder, review of chain-of-title documentation, and consultation of copyright registration records.

Despite these norms and its own sophistication, StreamNow failed to undertake any reasonable due diligence before acquiring and distributing the 217 Aurelius titles through MDD. Specifically, StreamNow failed to:

• Contact Aurelius or AMA directly to verify MDD's claimed authority to license Aurelius content;

• Request and review chain-of-title documentation linking MDD's purported rights back to Aurelius;

• Conduct even a basic search of U.S. Copyright Office records, which would have confirmed Aurelius's ownership of the titles and the absence of any recorded transfer to MDD;

• Investigate the background and credentials of MDD and its sole member, Franklin Ogilvie, including his former employment at Aurelius and the circumstances of his departure; or

• Require customary representations, warranties, and indemnities from MDD regarding its authority to license the content—or, if such provisions were included in the MDD-StreamNow agreement, to take reasonable steps to verify their accuracy.

StreamNow's failure to conduct any meaningful verification of MDD's authority is especially egregious given the sheer size of the catalog at issue—217 titles from a single, well-known global media conglomerate. A transaction of this magnitude involving content from a publicly traded media company should have triggered heightened scrutiny, not blind reliance on an intermediary's self-serving representations.

StreamNow's reliance on MDD's representations, without independent verification, does not constitute a valid defense to copyright infringement. It is black-letter law that a licensee's good faith belief in its rights does not shield it from liability for infringement where the purported licensor had no authority to grant the license. See, e.g., Maverick Recording Co. v. Harper, 598 F.3d 193, 198 (5th Cir. 2010); Peer Int'l Corp. v. Pausa Records, Inc., 909 F.2d 1332, 1336 (9th Cir. 1990). StreamNow's due diligence failures do not negate liability; they reinforce the willfulness of the infringement.

VI. Legal Basis for Aurelius's Claims

A. Federal Copyright Infringement (17 U.S.C. §§ 106, 501)

StreamNow has violated Aurelius's exclusive rights under 17 U.S.C. § 106, including the right of reproduction (§ 106(1)), the right of distribution (§ 106(3)), and the right of public performance (§ 106(4)), with respect to each of the 217 audiovisual works identified in Exhibit A. Each unauthorized reproduction, distribution, and public performance of each of the 217 works constitutes a separate act of infringement under 17 U.S.C. § 501.

Aurelius has standing to bring claims for copyright infringement as the registered owner of all 217 works at issue. Infringement is established by StreamNow's unauthorized reproduction, distribution, and public performance of the works. There is no factual dispute as to copying: StreamNow has made available and transmitted to its users verbatim, unaltered copies of the 217 audiovisual works, as ingested from MDD. The elements of Aurelius's claims are straightforward and dispositive.

B. Willful Infringement

The infringement at issue is willful within the meaning of 17 U.S.C. § 504(c)(2), supporting an award of enhanced statutory damages of up to $150,000 per work infringed. Willful infringement exists where the infringer knew or should have known that its conduct constituted copyright infringement, or acted with reckless disregard for the rights of the copyright owner.

The following factors, individually and collectively, establish that StreamNow's infringement was willful:

1. Failure to Conduct Reasonable Due Diligence. As described in Section V.D above, StreamNow failed to take any reasonable steps to verify MDD's authority to license the Aurelius catalog, despite StreamNow's sophistication and the magnitude of the transaction.

2. Ogilvie's Known Former Employment at Aurelius. Franklin Ogilvie's prior employment at Aurelius Media Americas, and the circumstances of his departure, should have raised obvious red flags for any reasonable content acquirer regarding the provenance and legitimacy of the content being offered through MDD. A basic inquiry into MDD's principals would have revealed Ogilvie's background and prompted further investigation.

3. Scale of the Infringement. The infringement involves 217 individual titles—including major film franchises and award-winning television series—exploited over a period of approximately 22 months. This is not a case of incidental or de minimis use; it is a commercial-scale appropriation of a substantial portion of a major media company's content library.

4. StreamNow's Sophistication. StreamNow is a major content aggregation platform with significant financial and operational resources, staffed by experienced content acquisition professionals who are expected to understand and comply with copyright law and industry licensing practices.

5. Continued Exploitation After Notice. StreamNow continued to exploit the Aurelius content even after Aurelius raised concerns through Raj Anantharam's inquiry in late October and early November 2025, which prompted Sandra Yee's November 3, 2025 email. StreamNow's continued distribution of the content after being put on inquiry notice of the rights issues further demonstrates willfulness and reckless disregard.

C. DMCA Safe Harbor Does Not Apply

StreamNow does not qualify for the safe harbor protections of the Digital Millennium Copyright Act, 17 U.S.C. § 512. Section 512 provides limited liability protection to certain "service providers" that act as passive conduits or hosts for user-generated content. StreamNow does not operate as a passive hosting service or user-generated content platform.

To the contrary, StreamNow actively curates, selects, acquires (or purports to acquire), licenses (or purports to license), prices, organizes, markets, and monetizes the content available on its platform. StreamNow exercises full editorial control over its catalog selection, determines pricing tiers and subscription structures, and manages the geographic availability of content across its fourteen-country footprint. StreamNow's content is not uploaded by users; it is procured and ingested by StreamNow itself through affirmative commercial transactions with content suppliers.

StreamNow's business model—that of a curated, commercially operated streaming platform—places it squarely outside the scope of § 512's safe harbor protections, which were designed to protect neutral intermediaries, not active commercial exploiters of copyrighted content. See Viacom Int'l, Inc. v. Crowne Albany Partners LLC, Inc., 676 F.3d 19, 38 (2d Cir. 2012); UMG Recordings, Inc. v. Shelter Capital Partners LLC, 718 F.3d 1006, 1014 (9th Cir. 2013).

D. Supplemental State Law Claims

In addition to its federal copyright claims, Aurelius has viable claims under California state law.

Unfair Competition (Cal. Bus. & Prof. Code § 17200). StreamNow's unauthorized distribution and monetization of Aurelius content constitutes an unlawful, unfair, and fraudulent business practice within the meaning of California Business and Professions Code § 17200 et seq. By distributing copyrighted content without authorization, StreamNow has engaged in conduct that violates federal law and that provides StreamNow with an unfair competitive advantage over platforms that pay fair market rates for licensed content. Aurelius is entitled to restitution, disgorgement, and injunctive relief under § 17200.

Tortious Interference with Prospective Economic Advantage. StreamNow's unauthorized availability of Aurelius content—at lower price points and through unauthorized channels—has demonstrably reduced Aurelius's licensing leverage with authorized platforms and has disrupted Aurelius's existing and prospective licensing relationships. StreamNow's conduct has interfered with Aurelius's ability to negotiate fair market value licenses for its content, causing Aurelius to suffer direct and consequential economic harm.

E. Claims Against MDD and Ogilvie

Aurelius expressly reserves all rights to pursue separate claims against Meridian Digital Distributors, LLC and Franklin Ogilvie, individually, for contributory copyright infringement, inducement of infringement, vicarious copyright infringement, breach of the June 30, 2021 Separation Agreement (including the intellectual property restrictions and non-compete provisions thereof), misappropriation of trade secrets, fraud, and any other applicable causes of action. Nothing in this letter, and no resolution of the claims against StreamNow, shall be construed as a waiver or release of any claims against MDD, Ogilvie, or any other party.

VII. Damages

A. Revenue Attributable to Infringing Content

Aurelius has retained CipherTrace Analytics, LLC, a nationally recognized digital forensics and data analytics firm, to conduct a forensic analysis of StreamNow's exploitation of the 217 Aurelius titles. Based on CipherTrace's analysis—which utilized available viewership data, platform analytics, pricing structures, and industry benchmarks—StreamNow has generated an estimated $38.6 million in revenue directly attributable to the unauthorized exploitation of the 217 Aurelius titles over the 22-month infringement period. This estimate is broken down as follows:

• Subscription revenue allocable to Aurelius titles: $22.4 million, based on CipherTrace's refined viewership share analysis and premium-tier weighting model, which apportions StreamNow's subscription revenue to individual titles based on their contribution to viewer engagement, subscriber acquisition, and subscriber retention.

• Advertising revenue (AVOD tier) allocable to Aurelius titles: $9.7 million, representing advertising revenue earned on ad-supported streams of the 217 Aurelius titles across all territories.

• Sublicensing fees received from FAST channel operators: $6.5 million, representing fees paid to StreamNow by Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd for content bundles that included the Aurelius titles.

These figures are preliminary and are expected to increase upon receipt of a complete accounting from StreamNow and further refinement of the forensic analysis.

B. Aurelius's Lost Licensing Revenue

In addition to StreamNow's profits, Aurelius has suffered lost licensing revenue estimated at $14.2 million. This figure represents the fair market value of a comparable arm's-length license for a catalog of 217 titles of similar quality, commercial appeal, and market positioning over a 22-month term in the relevant territories, as determined by reference to Aurelius's existing licensing agreements with authorized streaming platforms, MVPDs, and content distributors. The unauthorized availability of Aurelius content on StreamNow and its sublicensed FAST channels has undercut Aurelius's ability to license the same content to authorized platforms at fair market rates, resulting in direct lost revenue and diminished licensing value.

C. Total Damages

Under 17 U.S.C. § 504(b), Aurelius is entitled to recover its actual damages, plus any additional profits of the infringer that are attributable to the infringement and are not taken into account in computing actual damages. Preliminary economic modeling conducted by Hargrove Economic Consulting Group, LLC, a nationally recognized economic consulting firm specializing in intellectual property damages, estimates net recoverable damages under § 504(b)—calculated as the sum of Aurelius's actual damages and StreamNow's attributable profits, with appropriate apportionment to avoid double-counting—at $41.3 million.

Alternatively, Aurelius may elect to recover statutory damages under 17 U.S.C. § 504(c) in lieu of actual damages and profits. For the 189 timely-registered works, Aurelius may elect statutory damages of up to $150,000 per work for willful infringement under § 504(c)(2). Applied across all 217 works (including the 28 works registered after the commencement of infringement, which carry a maximum of $30,000 per work for non-willful infringement under § 504(c)(1)), the total potential statutory damages exposure is substantial. For the 189 timely-registered works alone, the maximum statutory damages award is $28,350,000 (189 × $150,000). For all 217 works at the maximum applicable rate, the total statutory damages exposure is up to $29,190,000 (189 × $150,000 + 28 × $30,000). Aurelius reserves the right to elect between actual damages and profits or statutory damages at any time prior to the entry of final judgment, as permitted by law.

D. Attorneys' Fees and Costs

For the 189 works with timely U.S. copyright registrations, Aurelius is entitled to recover its reasonable attorneys' fees and full costs of this action under 17 U.S.C. § 505. Given the scope and complexity of this matter, and the willful nature of StreamNow's infringement, Aurelius anticipates that its attorneys' fees and costs will be substantial and will be sought in full.

VIII. Specific Demands

In light of the foregoing, Aurelius Global Media Group PLC, through its counsel, hereby demands that StreamNow Holdings, Inc. take the following actions immediately:

Demand 1: Immediate Cessation. StreamNow shall immediately cease and desist from all unauthorized reproduction, distribution, public performance, and any other exploitation of the 217 Aurelius-owned audiovisual works identified in this letter and in the attached Exhibit A. This demand applies to all StreamNow platforms, applications, interfaces, servers, content delivery networks, and any other systems or channels through which the Aurelius content has been or is being made available, in all territories worldwide.

Demand 2: Complete Removal. StreamNow shall remove all Aurelius content from the StreamNow platform—including all versions, copies, and cached instances—in all territories and from all sublicensed channels, within five (5) business days of receipt of this letter. StreamNow shall further ensure that all downstream sublicensees, including but not limited to Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd, are immediately directed in writing to remove all Aurelius content from their respective FAST channels and any other distribution outlets, and that such removal is completed within the same five-business-day period.

Demand 3: Written Confirmation. StreamNow shall provide written confirmation to Calderwood & Harkness LLP, at the address set forth below, within ten (10) business days of receipt of this letter, certifying that: (a) all Aurelius content has been removed from the StreamNow platform in all territories; (b) all copies of Aurelius content have been deleted from StreamNow's servers, content delivery networks, and backup systems; and (c) all downstream sublicensees have been directed to remove, and have confirmed the removal of, all Aurelius content from their respective channels and platforms.

Demand 4: Full Accounting. StreamNow shall provide a complete and detailed accounting of all revenues derived from the exploitation of the 217 Aurelius titles throughout the entire infringement period, including but not limited to: subscription revenue, advertising revenue (including CPM rates and impression counts), sublicensing fees, transactional revenue, promotional revenue, and any other form of monetization. The accounting shall be broken down by (i) individual title, (ii) territory, (iii) time period (monthly, at minimum), and (iv) revenue stream. The accounting shall be certified by an officer of StreamNow and shall be accompanied by supporting documentation sufficient to verify its accuracy.

Demand 5: Payment of Damages. StreamNow shall pay damages to Aurelius in an amount not less than $41,300,000 (forty-one million three hundred thousand dollars), representing Aurelius's preliminary estimate of net recoverable damages (comprising actual damages plus StreamNow's attributable profits), subject to further adjustment upward upon receipt of a complete accounting from StreamNow and completion of Aurelius's damages analysis. Aurelius reserves all rights to seek additional or alternative relief, including statutory damages, in any subsequent litigation.

Demand 6: Preservation of Evidence. StreamNow shall immediately implement a litigation hold and preserve all documents, communications, records, data, and electronically stored information ("ESI") relating in any way to the acquisition, ingestion, storage, distribution, sublicensing, marketing, promotion, and monetization of the 217 Aurelius titles, including without limitation: (a) all correspondence, agreements, and communications with Meridian Digital Distributors, LLC and Franklin Ogilvie; (b) all correspondence, agreements, and communications with the four identified FAST channel sublicensees; (c) all internal communications relating to the acquisition or licensing of the Aurelius content; (d) all viewership data, analytics, and reports relating to the Aurelius titles; (e) all financial records, invoices, and revenue reports relating to the Aurelius titles; and (f) all metadata, system logs, and technical records relating to the ingestion, storage, and distribution of the Aurelius content. Any destruction, alteration, or concealment of relevant evidence will be viewed as spoliation and will be the subject of appropriate motions and adverse inference requests in any subsequent litigation.

IX. Response Window and Consequences of Non-Compliance

StreamNow is afforded thirty (30) calendar days from the date of this letter—that is, no later than April 13, 2026—to respond substantively to the demands set forth herein and to commence good-faith settlement negotiations with Aurelius and its counsel.

If StreamNow fails to comply with the demands set forth in this letter, or fails to engage in meaningful settlement discussions within the 30-day response window, Aurelius is prepared to, and will, file a complaint in the United States District Court for the Central District of California, Western Division (Los Angeles), asserting claims for:

(a) Copyright infringement under 17 U.S.C. §§ 106 and 501;

(b) Contributory copyright infringement;

(d) Unfair business practices under California Business and Professions Code § 17200 et seq.; and

(e) Tortious interference with prospective economic advantage.

In connection with the filing of the complaint, Aurelius will also seek emergency injunctive relief, including a temporary restraining order and a preliminary injunction, requiring the immediate removal of all Aurelius content from the StreamNow platform and all sublicensed channels, and prohibiting StreamNow from any further reproduction, distribution, or public performance of Aurelius content pending final resolution of the action.

Aurelius expressly reserves all rights and remedies available to it under applicable federal and state law, including but not limited to the right to seek enhanced statutory damages for willful infringement under 17 U.S.C. § 504(c)(2), reasonable attorneys' fees under 17 U.S.C. § 505, full costs of the action, prejudgment interest, and permanent injunctive relief.

X. Reservation of Rights

This letter is not intended to be, and shall not be construed as, a complete or exhaustive statement of all facts known to Aurelius, all claims available to Aurelius, or all remedies that Aurelius may seek. The facts and legal theories set forth herein are presented in summary form and are based on the information available to Aurelius and its counsel as of the date of this letter. Aurelius's investigation is ongoing, and additional facts, claims, and damages may be identified as the investigation continues and as further information becomes available.

Nothing in this letter constitutes, or shall be construed as, a waiver of any of Aurelius's rights, claims, or remedies, whether known or unknown, whether arising under federal or state law, and whether based on theories of direct infringement, contributory infringement, vicarious liability, inducement, contract, tort, or equity. All such rights, claims, and remedies are expressly reserved.

All rights to pursue claims against Meridian Digital Distributors, LLC, Franklin Ogilvie, individually, and any other persons or entities involved in the unauthorized exploitation of Aurelius content—including, without limitation, the officers, directors, members, agents, and employees of MDD—are separately and independently reserved.

Aurelius further reserves the right to seek recovery of all enforcement costs incurred in connection with this matter, including but not limited to attorneys' fees, expert witness fees, forensic analysis costs, and all other costs and expenses.

XI. Communications and Direction for Response

All communications and responses regarding this matter should be directed exclusively to the undersigned:

Marcus Delgado, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8217

Email: mdelgado@calderwoodharkness.com

If StreamNow is or intends to be represented by outside counsel in this matter, we request that such counsel identify themselves promptly and that all future correspondence and communications be directed through counsel. We are aware that StreamNow's outside litigation counsel is Grantham Roth & Pearce LLP, and specifically Victoria Langford, Partner, IP Litigation, located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071. A copy of this letter is being provided to Ms. Langford as a courtesy.

XII. Closing

Aurelius strongly urges StreamNow to take this matter with the seriousness it warrants and to respond promptly and constructively to the demands set forth in this letter. The unauthorized exploitation of 217 copyrighted audiovisual works over a 22-month period represents a substantial and ongoing violation of Aurelius's rights, and the resulting damages are significant and growing.

Aurelius's preference is to resolve this matter through good-faith negotiation and a fair settlement that appropriately compensates Aurelius for the harm it has suffered and ensures the immediate cessation of all infringing activity. However, if StreamNow fails to engage meaningfully within the timeframe specified, Aurelius is fully prepared to pursue all available legal remedies through litigation, including emergency injunctive relief, to protect its intellectual property rights.

We look forward to hearing from you or your counsel no later than April 13, 2026.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Marcus Delgado Partner, intellectual Property Litigation 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8217 Facsimile: (310) 556-8201

Email: mdelgado@calderwoodharkness.com

cc:

Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC (via email)

Victoria Langford, Esq., Grantham Roth & Pearce LLP, 555 South Flower Street, Suite 4200, Los Angeles, CA 90071 (via email and U.S. mail)

Enclosure:

Exhibit A — Schedule of 217 Aurelius-Owned Audiovisual Works at Issue (with U.S. Copyright Office Registration Numbers)

CALDERWOOD & HARKNESS LLP ATTORNEYS AT LAW
1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8200 Facsimile: (310) 556-8201 www.calderwoodharkness.com
March 14, 2026
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA EMAIL (trennert@streamnow.com)
Tobias Rennert, Esq. General Counsel StreamNow Holdings, Inc. 3400 Wilshire Boulevard, Suite 1800 Los Angeles, CA 90010
Re: Unauthorized Reproduction, Distribution, and Public Performance of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Cessation, Removal, Accounting, and Payment of Damages
Dear Mr. Rennert:
I. Introduction and Identification of Counsel and Client
This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company duly incorporated and existing under the laws of England and Wales (Companies House Registration No. 08724561), with its principal offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom, and its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. We are authorized to act on behalf of both Aurelius and AMA in connection with the matters set forth in this letter.
Aurelius is a publicly traded media and entertainment conglomerate whose ordinary shares are listed on the London Stock Exchange's AIM market under the ticker symbol AGLM, and whose American Depositary Receipts ("ADRs") are traded over-the-counter in the United States. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion), making it one of the leading independent media companies operating globally. Aurelius owns, controls, and exploits a content library comprising over 4,200 film and television titles across all media, formats, and territories worldwide.
Calderwood & Harkness LLP has been fully authorized by Aurelius and AMA to take all steps necessary and appropriate to protect Aurelius's intellectual property rights in connection with the infringing conduct described herein, including, without limitation, the commencement and prosecution of litigation in any court of competent jurisdiction.
The purpose of this letter is to formally demand that StreamNow Holdings, Inc. ("StreamNow" or "the Company") immediately cease and desist from all infringing activity involving Aurelius-owned copyrighted audiovisual works, and to set forth in detail the factual and legal basis for Aurelius's claims and the specific relief it requires. We urge you to treat this communication with the utmost seriousness.
II. Identification of StreamNow Holdings, Inc.
StreamNow Holdings, Inc. is a corporation organized and existing under the laws of the State of Delaware (Delaware Secretary of State File No. 7291843), with its principal place of business located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a direct-to-consumer "super-aggregator" streaming platform that bundles content from multiple studios, networks, and independent distributors into a single subscription-based or advertising-supported ("AVOD") interface. According to publicly available information and industry reporting, StreamNow's platform is currently available to consumers in fourteen (14) countries, including the United States, Canada, the United Kingdom, Australia, Germany, France, Brazil, Mexico, Japan, South Korea, India, Spain, Italy, and the Netherlands.
In addition to its direct-to-consumer operations, StreamNow sublicenses content bundles—including, as detailed below, Aurelius-owned content—to third-party multichannel video programming distributors ("MVPDs") and free ad-supported streaming television ("FAST") channel operators, thereby extending the reach and distribution of the content it purports to have licensed.
StreamNow is a privately held company. According to regulatory filings, industry reports, and information available through Bramwell Health IT and other data sources, majority ownership of StreamNow (approximately 62% of fully diluted equity) is held by Pinnacle Ventures Fund III, LP, a San Francisco-based growth equity fund that led StreamNow's $145 million Series C financing round in June 2022. StreamNow's estimated revenue for fiscal year 2025 is approximately $312 million, placing it among the largest independent streaming aggregation platforms in the United States. StreamNow is, by any measure, a sophisticated commercial enterprise with access to substantial financial, legal, and operational resources.
III. The Copyrighted Works at Issue
Aurelius is the sole and exclusive owner of the United States copyrights in at least two hundred seventeen (217) audiovisual works that StreamNow has reproduced, distributed, and publicly performed without authorization, license, or consent of any kind. These 217 titles comprise one hundred forty-two (142) feature films and seventy-five (75) television series, the latter totaling one thousand thirty-eight (1,038) individual episodes. The unauthorized exploitation of this catalog represents a massive and systematic appropriation of Aurelius's most valuable creative assets.
Among the works at issue are several of Aurelius's flagship franchises and marquee titles, including but not limited to:
• The "Meridian" Franchise: A series of six (6) interconnected feature films constituting one of Aurelius's most commercially successful film properties, with combined worldwide theatrical box office revenue of approximately $1.43 billion. The "Meridian" films are tentpole releases that anchor Aurelius's theatrical distribution strategy and generate significant downstream licensing, merchandising, and ancillary revenue.
• The "Iron Compass" Series: A four-season, forty-eight-episode (48-episode) original television series that is Aurelius's highest-rated original scripted program, drawing an average of 9.2 million UK viewers per episode during its initial broadcast run, with substantial viewership across multiple international territories.
• The "Thornfield" Period Drama Catalog: A collection of twelve (12) critically acclaimed period drama titles that have collectively won seven (7) British Academy of Film and Television Arts ("BAFTA") awards, representing a cornerstone of Aurelius's premium scripted content library and a perennial driver of international licensing revenue.
A complete schedule identifying each of the 217 titles at issue, together with corresponding United States Copyright Office registration numbers and other identifying information, is attached hereto as Exhibit A and incorporated herein by reference.
Copyright Registration Status. One hundred eighty-nine (189) of the 217 titles at issue have valid, timely United States copyright registrations—that is, registrations that were either made within three months of the work's first publication or made prior to the commencement of StreamNow's infringement. As a result, those 189 works are fully eligible for an award of statutory damages and reasonable attorneys' fees under 17 U.S.C. §§ 504(c) and 505. The remaining twenty-eight (28) titles have United States copyright registrations that, while valid, were obtained after the commencement of StreamNow's infringing conduct (registrations filed and issued between May 2024 and October 2025). Those 28 titles remain eligible for an award of actual damages and profits under 17 U.S.C. § 504(b).
The registration details for all 217 titles have been independently verified through a comprehensive search of the United States Copyright Office's public records, conducted by Lexington IP Services, Inc., a nationally recognized intellectual property search and due diligence firm, and completed on January 22, 2026. Aurelius's chain of title for each of the 217 works has been confirmed through review of chain-of-title documentation, assignment records, and corporate records, and is complete and unbroken in all respects.
IV. The Unauthorized Conduct
A. Nature of the Infringement
StreamNow has, without Aurelius's authorization, license, consent, or any other form of permission, engaged in the following infringing conduct with respect to all 217 Aurelius-owned audiovisual works:
1. Reproduction. StreamNow has reproduced the 217 titles by ingesting digital copies of those works into StreamNow's content management systems, servers, and platform library, in violation of Aurelius's exclusive right of reproduction under 17 U.S.C. § 106(1).
2. Distribution. StreamNow has distributed the 217 titles by making them available for on-demand streaming to StreamNow's paying subscribers and ad-supported users, thereby distributing copies of the works to the public, in violation of Aurelius's exclusive right of distribution under 17 U.S.C. § 106(3).
3. Public Performance. StreamNow has publicly performed the 217 titles by transmitting them—via streaming technology over the Internet and through connected device applications—to StreamNow's user base, thereby publicly performing those works by means of a device or process, in violation of Aurelius's exclusive right of public performance under 17 U.S.C. § 106(4).
Each of the foregoing acts constitutes a separate and independent violation of Aurelius's exclusive rights under the Copyright Act, 17 U.S.C. § 106. StreamNow's conduct is not the product of isolated or inadvertent error; rather, it reflects a sustained, commercial-scale exploitation of a massive catalog of copyrighted works over an extended period of time and across multiple territories.
B. Duration and Geographic Scope
Based on Aurelius's investigation to date, the infringement period spans approximately twenty-two (22) months, commencing on or about April 1, 2024, and continuing through at least January 31, 2026. Indeed, as of the date of this letter, Aurelius has reason to believe that the infringing activity is ongoing. Throughout this period, Aurelius content has been made available through the StreamNow platform to users in the United States, Canada, Australia, and at least eleven (11) additional territories in which StreamNow operates, encompassing a substantial portion of the global English-language streaming market as well as significant non-English-language markets.
The duration and scope of the infringement are significant. Over the course of nearly two years, StreamNow has derived commercial benefit from Aurelius's content on a continuous basis, embedding that content deeply into its platform's catalog, marketing materials, recommendation algorithms, and subscriber value proposition.
C. Sublicensing to FAST Channel Operators
StreamNow has materially compounded the infringement by sublicensing content bundles containing Aurelius-owned titles to at least four (4) third-party FAST channel operators, thereby extending the unauthorized reproduction, distribution, and public performance of Aurelius's copyrighted works far beyond StreamNow's own direct-to-consumer platform. The FAST channel operators to which StreamNow has sublicensed Aurelius content include:
1. Brindoval Channel Networks, Inc., a Texas corporation headquartered in Dallas, Texas;
2. BrightLoop Media, LLC, a Florida limited liability company headquartered in Miami, Florida;
3. Velvet Stream Partners, LP, a Canadian limited partnership headquartered in Toronto, Ontario, Canada; and
4. Pacific Lantern Digital Pty Ltd, an Australian proprietary limited company headquartered in Sydney, New South Wales, Australia.
Each of these sublicenses created additional, unauthorized channels of distribution and public performance for the Aurelius content, multiplying the scope of the infringement and the resulting harm to Aurelius. StreamNow's sublicensing of content that it had no right to sublicense demonstrates a reckless disregard for the intellectual property rights of content owners and underscores the willful nature of StreamNow's conduct.
D. Discovery of the Infringement
Aurelius first discovered StreamNow's unauthorized exploitation of Aurelius content on October 15, 2025, when Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, identified multiple Aurelius-owned titles appearing on the StreamNow platform during a routine audit of unauthorized distribution channels. Ms. Kowalski immediately initiated an internal review and confirmed that the titles in question were being streamed through StreamNow without any corresponding license or authorization in Aurelius's rights management systems.
On October 22, 2025, the matter was escalated to Fiona Hartwell, Aurelius's General Counsel, and a formal internal investigation was commenced. The investigation rapidly confirmed that the scope of the unauthorized exploitation extended to at least 217 distinct titles across StreamNow's platform and sublicensed FAST channels.
In furtherance of its enforcement efforts, Aurelius retained UK counsel, Bexley Marsh Solicitors LLP, of London, England, who were formally engaged on November 18, 2025, to investigate and advise on the international aspects of the matter. Aurelius subsequently retained this firm, Calderwood & Harkness LLP, as its United States counsel, with the engagement formally opened on February 12, 2026, under Matter No. 1017-00003, to investigate and pursue all available claims in the United States.
V. StreamNow Has No Valid License — Rejection of the MDD Sublicense Defense
A. Sandra Yee's November 3, 2025 Email
Aurelius is aware that StreamNow may seek to assert a defense based on its purported sublicense from a third-party intermediary. Specifically, in an email dated November 3, 2025, Sandra Yee, StreamNow's Vice President of Content Acquisition, represented to Raj Anantharam, Aurelius's Senior Vice President of Content Licensing & Distribution, that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC ("MDD"), a Los Angeles-based content aggregator. In that email, Ms. Yee referenced a "Content Distribution Agreement" between MDD and StreamNow that was allegedly executed on March 15, 2024, and which purportedly covered over 350 titles, including the 217 Aurelius-owned titles at issue in this matter.
This purported defense is wholly without merit, for the reasons set forth below.
B. MDD Is Not and Has Never Been an Authorized Distributor
Meridian Digital Distributors, LLC (California Secretary of State File No. 202115729430) is a California limited liability company whose sole member and manager is Franklin Ogilvie. MDD was incorporated in late 2021, shortly after Mr. Ogilvie's departure from Aurelius Media Americas, Inc. under the circumstances described in Section V.C below.
Aurelius states, unequivocally and categorically, that:
• Aurelius has never granted MDD any license, sublicense, distribution authority, or any other form of authorization, whether written or oral, express or implied, over any Aurelius-owned content whatsoever.
• MDD is not and has never been an authorized distributor, agent, representative, sublicensee, or affiliate of Aurelius in any capacity.
• Aurelius has no contractual, commercial, or business relationship of any kind with MDD.
• Any purported "Content Distribution Agreement" between MDD and StreamNow, to the extent it purports to convey rights in Aurelius-owned content, is void and of no legal effect as to Aurelius's copyrights. One cannot convey rights one does not possess; nemo dat quod non habet.
C. Franklin Ogilvie's Background and Separation Agreement
Franklin Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 until June 30, 2021. During his tenure, Mr. Ogilvie was involved in certain aspects of Aurelius's content licensing operations in the Americas, but he held no authority to negotiate, execute, or grant licenses independently, and his role was subject to multiple levels of managerial approval and oversight.
Mr. Ogilvie's employment with Aurelius Media Americas was terminated effective June 30, 2021, following an internal investigation that revealed unauthorized access to Aurelius's proprietary content management systems and the downloading of confidential rights management data. The circumstances of Mr. Ogilvie's departure are directly relevant to the instant matter, as they establish that Mr. Ogilvie was known to have engaged in conduct inconsistent with the proper handling of Aurelius's intellectual property even before he founded MDD.
On June 30, 2021, in connection with his separation from Aurelius Media Americas, Mr. Ogilvie executed a separation agreement and general release (the "Separation Agreement") that included, among other provisions:
(a) A covenant not to compete with Aurelius or any of its subsidiaries or affiliates in the content licensing and distribution business for a period of two (2) years following his separation;
(b) A covenant not to solicit Aurelius's employees, clients, licensees, or business partners;
(c) An explicit and unambiguous prohibition on the use, disclosure, or exploitation of any Aurelius intellectual property, trade secrets, confidential information, or proprietary data; and
(d) A comprehensive release of any claims Mr. Ogilvie might have had to any rights in or to Aurelius content.
Mr. Ogilvie had no authority, at any time during or after his employment, to license, sublicense, distribute, or otherwise exploit Aurelius content, whether through MDD or any other entity. Any representations made by Mr. Ogilvie or MDD to StreamNow regarding rights to Aurelius content were false, unauthorized, and made without any basis whatsoever.
D. StreamNow's Due Diligence Failures
StreamNow is a sophisticated content aggregation platform with estimated annual revenues of $312 million, backed by a $145 million investment from a major growth equity fund, and operating across fourteen countries. As such, StreamNow is—and at all relevant times was—fully aware of the critical importance of verifying rights ownership and chain of title before acquiring and distributing copyrighted content. The content licensing industry has well-established norms and practices for conducting rights verification, including direct confirmation with the rights holder, review of chain-of-title documentation, and consultation of copyright registration records.
Despite these norms and its own sophistication, StreamNow failed to undertake any reasonable due diligence before acquiring and distributing the 217 Aurelius titles through MDD. Specifically, StreamNow failed to:
• Contact Aurelius or AMA directly to verify MDD's claimed authority to license Aurelius content;
• Request and review chain-of-title documentation linking MDD's purported rights back to Aurelius;
• Conduct even a basic search of U.S. Copyright Office records, which would have confirmed Aurelius's ownership of the titles and the absence of any recorded transfer to MDD;
• Investigate the background and credentials of MDD and its sole member, Franklin Ogilvie, including his former employment at Aurelius and the circumstances of his departure; or
• Require customary representations, warranties, and indemnities from MDD regarding its authority to license the content—or, if such provisions were included in the MDD-StreamNow agreement, to take reasonable steps to verify their accuracy.
StreamNow's failure to conduct any meaningful verification of MDD's authority is especially egregious given the sheer size of the catalog at issue—217 titles from a single, well-known global media conglomerate. A transaction of this magnitude involving content from a publicly traded media company should have triggered heightened scrutiny, not blind reliance on an intermediary's self-serving representations.
StreamNow's reliance on MDD's representations, without independent verification, does not constitute a valid defense to copyright infringement. It is black-letter law that a licensee's good faith belief in its rights does not shield it from liability for infringement where the purported licensor had no authority to grant the license. See, e.g., Maverick Recording Co. v. Harper, 598 F.3d 193, 198 (5th Cir. 2010); Peer Int'l Corp. v. Pausa Records, Inc., 909 F.2d 1332, 1336 (9th Cir. 1990). StreamNow's due diligence failures do not negate liability; they reinforce the willfulness of the infringement.
VI. Legal Basis for Aurelius's Claims
A. Federal Copyright Infringement (17 U.S.C. §§ 106, 501)
StreamNow has violated Aurelius's exclusive rights under 17 U.S.C. § 106, including the right of reproduction (§ 106(1)), the right of distribution (§ 106(3)), and the right of public performance (§ 106(4)), with respect to each of the 217 audiovisual works identified in Exhibit A. Each unauthorized reproduction, distribution, and public performance of each of the 217 works constitutes a separate act of infringement under 17 U.S.C. § 501.
Aurelius has standing to bring claims for copyright infringement as the registered owner of all 217 works at issue. Infringement is established by StreamNow's unauthorized reproduction, distribution, and public performance of the works. There is no factual dispute as to copying: StreamNow has made available and transmitted to its users verbatim, unaltered copies of the 217 audiovisual works, as ingested from MDD. The elements of Aurelius's claims are straightforward and dispositive.
B. Willful Infringement
The infringement at issue is willful within the meaning of 17 U.S.C. § 504(c)(2), supporting an award of enhanced statutory damages of up to $150,000 per work infringed. Willful infringement exists where the infringer knew or should have known that its conduct constituted copyright infringement, or acted with reckless disregard for the rights of the copyright owner.
The following factors, individually and collectively, establish that StreamNow's infringement was willful:
1. Failure to Conduct Reasonable Due Diligence. As described in Section V.D above, StreamNow failed to take any reasonable steps to verify MDD's authority to license the Aurelius catalog, despite StreamNow's sophistication and the magnitude of the transaction.
2. Ogilvie's Known Former Employment at Aurelius. Franklin Ogilvie's prior employment at Aurelius Media Americas, and the circumstances of his departure, should have raised obvious red flags for any reasonable content acquirer regarding the provenance and legitimacy of the content being offered through MDD. A basic inquiry into MDD's principals would have revealed Ogilvie's background and prompted further investigation.
3. Scale of the Infringement. The infringement involves 217 individual titles—including major film franchises and award-winning television series—exploited over a period of approximately 22 months. This is not a case of incidental or de minimis use; it is a commercial-scale appropriation of a substantial portion of a major media company's content library.
4. StreamNow's Sophistication. StreamNow is a major content aggregation platform with significant financial and operational resources, staffed by experienced content acquisition professionals who are expected to understand and comply with copyright law and industry licensing practices.
5. Continued Exploitation After Notice. StreamNow continued to exploit the Aurelius content even after Aurelius raised concerns through Raj Anantharam's inquiry in late October and early November 2025, which prompted Sandra Yee's November 3, 2025 email. StreamNow's continued distribution of the content after being put on inquiry notice of the rights issues further demonstrates willfulness and reckless disregard.
C. DMCA Safe Harbor Does Not Apply
StreamNow does not qualify for the safe harbor protections of the Digital Millennium Copyright Act, 17 U.S.C. § 512. Section 512 provides limited liability protection to certain "service providers" that act as passive conduits or hosts for user-generated content. StreamNow does not operate as a passive hosting service or user-generated content platform.
To the contrary, StreamNow actively curates, selects, acquires (or purports to acquire), licenses (or purports to license), prices, organizes, markets, and monetizes the content available on its platform. StreamNow exercises full editorial control over its catalog selection, determines pricing tiers and subscription structures, and manages the geographic availability of content across its fourteen-country footprint. StreamNow's content is not uploaded by users; it is procured and ingested by StreamNow itself through affirmative commercial transactions with content suppliers.
StreamNow's business model—that of a curated, commercially operated streaming platform—places it squarely outside the scope of § 512's safe harbor protections, which were designed to protect neutral intermediaries, not active commercial exploiters of copyrighted content. See Viacom Int'l, Inc. v. Crowne Albany Partners LLC, Inc., 676 F.3d 19, 38 (2d Cir. 2012); UMG Recordings, Inc. v. Shelter Capital Partners LLC, 718 F.3d 1006, 1014 (9th Cir. 2013).
D. Supplemental State Law Claims
In addition to its federal copyright claims, Aurelius has viable claims under California state law.
Unfair Competition (Cal. Bus. & Prof. Code § 17200). StreamNow's unauthorized distribution and monetization of Aurelius content constitutes an unlawful, unfair, and fraudulent business practice within the meaning of California Business and Professions Code § 17200 et seq. By distributing copyrighted content without authorization, StreamNow has engaged in conduct that violates federal law and that provides StreamNow with an unfair competitive advantage over platforms that pay fair market rates for licensed content. Aurelius is entitled to restitution, disgorgement, and injunctive relief under § 17200.
Tortious Interference with Prospective Economic Advantage. StreamNow's unauthorized availability of Aurelius content—at lower price points and through unauthorized channels—has demonstrably reduced Aurelius's licensing leverage with authorized platforms and has disrupted Aurelius's existing and prospective licensing relationships. StreamNow's conduct has interfered with Aurelius's ability to negotiate fair market value licenses for its content, causing Aurelius to suffer direct and consequential economic harm.
E. Claims Against MDD and Ogilvie
Aurelius expressly reserves all rights to pursue separate claims against Meridian Digital Distributors, LLC and Franklin Ogilvie, individually, for contributory copyright infringement, inducement of infringement, vicarious copyright infringement, breach of the June 30, 2021 Separation Agreement (including the intellectual property restrictions and non-compete provisions thereof), misappropriation of trade secrets, fraud, and any other applicable causes of action. Nothing in this letter, and no resolution of the claims against StreamNow, shall be construed as a waiver or release of any claims against MDD, Ogilvie, or any other party.
VII. Damages
A. Revenue Attributable to Infringing Content
Aurelius has retained CipherTrace Analytics, LLC, a nationally recognized digital forensics and data analytics firm, to conduct a forensic analysis of StreamNow's exploitation of the 217 Aurelius titles. Based on CipherTrace's analysis—which utilized available viewership data, platform analytics, pricing structures, and industry benchmarks—StreamNow has generated an estimated $38.6 million in revenue directly attributable to the unauthorized exploitation of the 217 Aurelius titles over the 22-month infringement period. This estimate is broken down as follows:
• Subscription revenue allocable to Aurelius titles: $22.4 million, based on CipherTrace's refined viewership share analysis and premium-tier weighting model, which apportions StreamNow's subscription revenue to individual titles based on their contribution to viewer engagement, subscriber acquisition, and subscriber retention.
• Advertising revenue (AVOD tier) allocable to Aurelius titles: $9.7 million, representing advertising revenue earned on ad-supported streams of the 217 Aurelius titles across all territories.
• Sublicensing fees received from FAST channel operators: $6.5 million, representing fees paid to StreamNow by Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd for content bundles that included the Aurelius titles.
These figures are preliminary and are expected to increase upon receipt of a complete accounting from StreamNow and further refinement of the forensic analysis.
B. Aurelius's Lost Licensing Revenue
In addition to StreamNow's profits, Aurelius has suffered lost licensing revenue estimated at $14.2 million. This figure represents the fair market value of a comparable arm's-length license for a catalog of 217 titles of similar quality, commercial appeal, and market positioning over a 22-month term in the relevant territories, as determined by reference to Aurelius's existing licensing agreements with authorized streaming platforms, MVPDs, and content distributors. The unauthorized availability of Aurelius content on StreamNow and its sublicensed FAST channels has undercut Aurelius's ability to license the same content to authorized platforms at fair market rates, resulting in direct lost revenue and diminished licensing value.
C. Total Damages
Under 17 U.S.C. § 504(b), Aurelius is entitled to recover its actual damages, plus any additional profits of the infringer that are attributable to the infringement and are not taken into account in computing actual damages. Preliminary economic modeling conducted by Hargrove Economic Consulting Group, LLC, a nationally recognized economic consulting firm specializing in intellectual property damages, estimates net recoverable damages under § 504(b)—calculated as the sum of Aurelius's actual damages and StreamNow's attributable profits, with appropriate apportionment to avoid double-counting—at $41.3 million.
Alternatively, Aurelius may elect to recover statutory damages under 17 U.S.C. § 504(c) in lieu of actual damages and profits. For the 189 timely-registered works, Aurelius may elect statutory damages of up to $150,000 per work for willful infringement under § 504(c)(2). Applied across all 217 works (including the 28 works registered after the commencement of infringement, which carry a maximum of $30,000 per work for non-willful infringement under § 504(c)(1)), the total potential statutory damages exposure is substantial. For the 189 timely-registered works alone, the maximum statutory damages award is $28,350,000 (189 × $150,000). For all 217 works at the maximum applicable rate, the total statutory damages exposure is up to $29,190,000 (189 × $150,000 + 28 × $30,000). Aurelius reserves the right to elect between actual damages and profits or statutory damages at any time prior to the entry of final judgment, as permitted by law.
D. Attorneys' Fees and Costs
For the 189 works with timely U.S. copyright registrations, Aurelius is entitled to recover its reasonable attorneys' fees and full costs of this action under 17 U.S.C. § 505. Given the scope and complexity of this matter, and the willful nature of StreamNow's infringement, Aurelius anticipates that its attorneys' fees and costs will be substantial and will be sought in full.
VIII. Specific Demands
In light of the foregoing, Aurelius Global Media Group PLC, through its counsel, hereby demands that StreamNow Holdings, Inc. take the following actions immediately:
Demand 1: Immediate Cessation. StreamNow shall immediately cease and desist from all unauthorized reproduction, distribution, public performance, and any other exploitation of the 217 Aurelius-owned audiovisual works identified in this letter and in the attached Exhibit A. This demand applies to all StreamNow platforms, applications, interfaces, servers, content delivery networks, and any other systems or channels through which the Aurelius content has been or is being made available, in all territories worldwide.
Demand 2: Complete Removal. StreamNow shall remove all Aurelius content from the StreamNow platform—including all versions, copies, and cached instances—in all territories and from all sublicensed channels, within five (5) business days of receipt of this letter. StreamNow shall further ensure that all downstream sublicensees, including but not limited to Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd, are immediately directed in writing to remove all Aurelius content from their respective FAST channels and any other distribution outlets, and that such removal is completed within the same five-business-day period.
Demand 3: Written Confirmation. StreamNow shall provide written confirmation to Calderwood & Harkness LLP, at the address set forth below, within ten (10) business days of receipt of this letter, certifying that: (a) all Aurelius content has been removed from the StreamNow platform in all territories; (b) all copies of Aurelius content have been deleted from StreamNow's servers, content delivery networks, and backup systems; and (c) all downstream sublicensees have been directed to remove, and have confirmed the removal of, all Aurelius content from their respective channels and platforms.
Demand 4: Full Accounting. StreamNow shall provide a complete and detailed accounting of all revenues derived from the exploitation of the 217 Aurelius titles throughout the entire infringement period, including but not limited to: subscription revenue, advertising revenue (including CPM rates and impression counts), sublicensing fees, transactional revenue, promotional revenue, and any other form of monetization. The accounting shall be broken down by (i) individual title, (ii) territory, (iii) time period (monthly, at minimum), and (iv) revenue stream. The accounting shall be certified by an officer of StreamNow and shall be accompanied by supporting documentation sufficient to verify its accuracy.
Demand 5: Payment of Damages. StreamNow shall pay damages to Aurelius in an amount not less than $41,300,000 (forty-one million three hundred thousand dollars), representing Aurelius's preliminary estimate of net recoverable damages (comprising actual damages plus StreamNow's attributable profits), subject to further adjustment upward upon receipt of a complete accounting from StreamNow and completion of Aurelius's damages analysis. Aurelius reserves all rights to seek additional or alternative relief, including statutory damages, in any subsequent litigation.
Demand 6: Preservation of Evidence. StreamNow shall immediately implement a litigation hold and preserve all documents, communications, records, data, and electronically stored information ("ESI") relating in any way to the acquisition, ingestion, storage, distribution, sublicensing, marketing, promotion, and monetization of the 217 Aurelius titles, including without limitation: (a) all correspondence, agreements, and communications with Meridian Digital Distributors, LLC and Franklin Ogilvie; (b) all correspondence, agreements, and communications with the four identified FAST channel sublicensees; (c) all internal communications relating to the acquisition or licensing of the Aurelius content; (d) all viewership data, analytics, and reports relating to the Aurelius titles; (e) all financial records, invoices, and revenue reports relating to the Aurelius titles; and (f) all metadata, system logs, and technical records relating to the ingestion, storage, and distribution of the Aurelius content. Any destruction, alteration, or concealment of relevant evidence will be viewed as spoliation and will be the subject of appropriate motions and adverse inference requests in any subsequent litigation.
IX. Response Window and Consequences of Non-Compliance
StreamNow is afforded thirty (30) calendar days from the date of this letter—that is, no later than April 13, 2026—to respond substantively to the demands set forth herein and to commence good-faith settlement negotiations with Aurelius and its counsel.
If StreamNow fails to comply with the demands set forth in this letter, or fails to engage in meaningful settlement discussions within the 30-day response window, Aurelius is prepared to, and will, file a complaint in the United States District Court for the Central District of California, Western Division (Los Angeles), asserting claims for:
(a) Copyright infringement under 17 U.S.C. §§ 106 and 501;
(b) Contributory copyright infringement;
(c) Inducement of copyright infringement;
(d) Unfair business practices under California Business and Professions Code § 17200 et seq.; and
(e) Tortious interference with prospective economic advantage.
In connection with the filing of the complaint, Aurelius will also seek emergency injunctive relief, including a temporary restraining order and a preliminary injunction, requiring the immediate removal of all Aurelius content from the StreamNow platform and all sublicensed channels, and prohibiting StreamNow from any further reproduction, distribution, or public performance of Aurelius content pending final resolution of the action.
Aurelius expressly reserves all rights and remedies available to it under applicable federal and state law, including but not limited to the right to seek enhanced statutory damages for willful infringement under 17 U.S.C. § 504(c)(2), reasonable attorneys' fees under 17 U.S.C. § 505, full costs of the action, prejudgment interest, and permanent injunctive relief.
X. Reservation of Rights
This letter is not intended to be, and shall not be construed as, a complete or exhaustive statement of all facts known to Aurelius, all claims available to Aurelius, or all remedies that Aurelius may seek. The facts and legal theories set forth herein are presented in summary form and are based on the information available to Aurelius and its counsel as of the date of this letter. Aurelius's investigation is ongoing, and additional facts, claims, and damages may be identified as the investigation continues and as further information becomes available.
Nothing in this letter constitutes, or shall be construed as, a waiver of any of Aurelius's rights, claims, or remedies, whether known or unknown, whether arising under federal or state law, and whether based on theories of direct infringement, contributory infringement, vicarious liability, inducement, contract, tort, or equity. All such rights, claims, and remedies are expressly reserved.
All rights to pursue claims against Meridian Digital Distributors, LLC, Franklin Ogilvie, individually, and any other persons or entities involved in the unauthorized exploitation of Aurelius content—including, without limitation, the officers, directors, members, agents, and employees of MDD—are separately and independently reserved.
Aurelius further reserves the right to seek recovery of all enforcement costs incurred in connection with this matter, including but not limited to attorneys' fees, expert witness fees, forensic analysis costs, and all other costs and expenses.
XI. Communications and Direction for Response
All communications and responses regarding this matter should be directed exclusively to the undersigned:
Marcus Delgado, Partner Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8217
Email: mdelgado@calderwoodharkness.com
If StreamNow is or intends to be represented by outside counsel in this matter, we request that such counsel identify themselves promptly and that all future correspondence and communications be directed through counsel. We are aware that StreamNow's outside litigation counsel is Grantham Roth & Pearce LLP, and specifically Victoria Langford, Partner, IP Litigation, located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071. A copy of this letter is being provided to Ms. Langford as a courtesy.
XII. Closing
Aurelius strongly urges StreamNow to take this matter with the seriousness it warrants and to respond promptly and constructively to the demands set forth in this letter. The unauthorized exploitation of 217 copyrighted audiovisual works over a 22-month period represents a substantial and ongoing violation of Aurelius's rights, and the resulting damages are significant and growing.
Aurelius's preference is to resolve this matter through good-faith negotiation and a fair settlement that appropriately compensates Aurelius for the harm it has suffered and ensures the immediate cessation of all infringing activity. However, if StreamNow fails to engage meaningfully within the timeframe specified, Aurelius is fully prepared to pursue all available legal remedies through litigation, including emergency injunctive relief, to protect its intellectual property rights.
We look forward to hearing from you or your counsel no later than April 13, 2026.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Marcus Delgado Partner, intellectual Property Litigation 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8217 Facsimile: (310) 556-8201
Email: mdelgado@calderwoodharkness.com
cc:
Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC (via email)
Victoria Langford, Esq., Grantham Roth & Pearce LLP, 555 South Flower Street, Suite 4200, Los Angeles, CA 90071 (via email and U.S. mail)
Enclosure:
Exhibit A — Schedule of 217 Aurelius-Owned Audiovisual Works at Issue (with U.S. Copyright Office Registration Numbers)

CALDERWOOD & HARKNESS LLP ATTORNEYS AT LAW

CALDERWOOD & HARKNESS LLP

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