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

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PRIVILEGED AND CONFIDENTIAL

CALDERWOOD & HARKNESS LLP Attorneys at Law

1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-7200 Facsimile: (310) 556-7201

600 Lexington Avenue, 38th Floor New York, New York 10022 Telephone: (212) 848-4500 Facsimile: (212) 848-4501

Wendy Schultz Senior Associate, intellectual Property Direct: (310) 556-7243

Email: wschultz@calderwoodharkness.com

March 14, 2026

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND ELECTRONIC MAIL

BrightLoop Media, LLC

Attn: General Counsel / Managing Member

2700 Biscayne Boulevard, Suite 900 Miami, Florida 33137

Re: Unauthorized Distribution and Public Performance of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Takedown and Preservation of Records

Matter Reference: 1017-00003

Dear General Counsel or Managing Member:

This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated in England and Wales under the Companies Act 2006 (Companies House Registration No. 08724561), with its registered office and principal place of business at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius operates in the United States through its wholly-owned subsidiary, Aurelius Media Americas, Inc. ("AMA"), a corporation organized and existing under the laws of the State of Delaware, with offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. As you may be aware, Aurelius is a major international media and entertainment conglomerate with fiscal year 2025 consolidated revenue of approximately £1.87 billion (approximately $2.36 billion USD), whose ordinary shares are admitted to trading on the AIM market of the London Stock Exchange under the ticker symbol AGLM. Aurelius and its affiliated entities own and control a content library encompassing more than 4,200 film and television titles, including numerous high-profile theatrical franchises, award-winning television series, and critically acclaimed catalog titles distributed worldwide.

We write to you on behalf of Aurelius to make a formal demand that BrightLoop Media, LLC ("BrightLoop") immediately cease all unauthorized reproduction, distribution, and public performance of Aurelius-owned copyrighted audiovisual content that is currently being exploited, without any authorization whatsoever from Aurelius, through BrightLoop's Free Ad-Supported Streaming Television ("FAST") channels and any related platforms or distribution mechanisms. As detailed below, the content at issue was unlawfully sublicensed to BrightLoop by StreamNow Holdings, Inc. ("StreamNow"), a Delaware corporation (Secretary of State File No. 7291843) headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, which itself purported to obtain the content through a fraudulent and wholly unauthorized chain of distribution originating with an entity called Meridian Digital Distributors, LLC ("MDD"). Neither MDD nor StreamNow has ever possessed any license, sublicense, or distribution authority from Aurelius with respect to any Aurelius-owned content. Accordingly, BrightLoop's ongoing exploitation of this content constitutes direct copyright infringement under federal law, and Aurelius demands that BrightLoop take the immediate corrective actions described in this letter.

I. BACKGROUND AND FACTUAL SUMMARY

A. Aurelius's Content Ownership

Aurelius and its subsidiaries hold all relevant United States copyrights in a catalog of at least 217 audiovisual works — comprising 142 feature films and 75 television series (encompassing 1,038 individual episodes) — that are the subject of this demand. Of these 217 works, 189 have been the subject of timely registrations with the United States Copyright Office, and the remaining 28 titles have also been registered with the Copyright Office, ensuring that Aurelius is entitled to the full panoply of remedies available under the Copyright Act for infringement of all 217 works. A comprehensive listing of the 217 titles at issue is set forth in Exhibit A attached hereto.

The Aurelius content library at issue includes some of the most commercially and critically significant audiovisual properties in the international entertainment market. Key properties include, without limitation:

• The "Meridian" franchise, consisting of six theatrical feature films released between 2012 and 2024, with a combined worldwide theatrical gross of approximately $1.43 billion and substantial additional revenues from home entertainment, pay television, subscription video-on-demand ("SVOD"), and ancillary exploitation windows;

• The "Iron Compass" series, a four-season, 48-episode dramatic television series that averaged 9.2 million viewers per episode in the United Kingdom during its original broadcast run on Severin Enterprises, and which has been licensed for distribution in over 60 territories worldwide; and

• The "Thornfield" period drama catalog, comprising 12 separate titles (both feature-length productions and limited series) that have collectively been honored with seven British Academy of Film and Television Arts ("BAFTA") awards, three International Emmy Awards, and numerous additional nominations and accolades.

These properties, together with the remainder of the 217 works identified in Exhibit A, represent a significant portion of Aurelius's most valuable intellectual property assets. Aurelius has invested hundreds of millions of dollars in the development, production, marketing, and distribution of these works, and it manages and enforces its rights in this content aggressively and systematically across all distribution platforms and territories.

Aurelius has confirmed its unbroken chain of title for all 217 works through a comprehensive chain-of-title analysis and United States Copyright Office records search completed by Lexington IP Services, Inc., an independent title search and clearance firm, on January 22, 2026. That analysis confirmed that Aurelius (directly or through its subsidiaries, with all rights having been properly assigned and recorded) is the sole and exclusive owner of all U.S. copyrights in each of the 217 works, including without limitation the exclusive rights of reproduction, distribution, and public performance under 17 U.S.C. § 106. No license, sublicense, assignment, or other grant of rights in any of these works has been made to MDD, StreamNow, BrightLoop, or any other party in the unauthorized distribution chain described below.

B. The Unauthorized Sublicensing Chain

Calderwood & Harkness's investigation has uncovered the following facts regarding the unauthorized sublicensing chain through which BrightLoop came to exploit Aurelius-owned content without authorization.

StreamNow Holdings, Inc. operates what it describes as a "super-aggregator" streaming platform that bundles content from multiple distributors and rights holders into subscription-based and ad-supported tiers, currently available to consumers in approximately 14 countries across North America, Europe, Latin America, and the Asia-Pacific region. StreamNow purported to obtain rights to the 217 Aurelius titles at issue through a document styled as a "Content Distribution Agreement" allegedly executed on or about March 15, 2024, with Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with its principal address listed at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

MDD is controlled by Franklin Ogilvie, who is its sole member and manager. Mr. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc., where he was employed from approximately 2017 through June 30, 2021. Mr. Ogilvie's employment with AMA was terminated on June 30, 2021, following an internal investigation conducted by AMA's Legal and Compliance departments, which uncovered evidence of unauthorized access to and misuse of Aurelius's proprietary content management systems, including unauthorized download and export of content metadata, technical specifications, and distribution key files. In connection with his departure, Mr. Ogilvie executed a separation agreement and general release dated June 30, 2021, which included, among other provisions, a non-competition covenant, a non-solicitation covenant, a comprehensive confidentiality obligation, and an explicit, unambiguous prohibition on the use, distribution, sublicensing, or other exploitation of any Aurelius intellectual property, trade secrets, or proprietary information following termination.

Despite these obligations, Mr. Ogilvie formed MDD and subsequently purported to license Aurelius-owned content to StreamNow — content over which neither he nor MDD has ever had any authority, license, or right of any kind. To be absolutely clear: Aurelius has never granted MDD any license, sublicense, distribution agreement, or any other form of authorization to reproduce, distribute, publicly perform, or otherwise exploit any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius in any capacity.

Consequently, StreamNow never acquired valid rights to any of the Aurelius content purportedly licensed to it by MDD. The March 15, 2024 Content Distribution Agreement between MDD and StreamNow — to the extent it purports to grant rights in Aurelius-owned content — is void and of no force or effect, as MDD had no rights to grant. StreamNow therefore had no authority to sublicense any Aurelius-owned content to BrightLoop or to any other party, and any purported sublicense from StreamNow to BrightLoop conveying rights in Aurelius content is similarly void and without legal effect.

C. BrightLoop's Receipt and Exploitation of Infringing Content

Calderwood & Harkness's investigation, including a comprehensive digital forensic analysis conducted by CipherTrace Analytics, LLC — a nationally recognized digital media forensics firm, under the direction of Dr. Nathan Frey, Director of Digital Media Forensics — has confirmed the following:

StreamNow sublicensed content bundles containing Aurelius-owned titles to BrightLoop Media, LLC, among other FAST channel operators. BrightLoop ingested these content bundles, integrated the Aurelius titles into its FAST channel programming, and has been and continues to distribute and publicly perform Aurelius's copyrighted audiovisual works through its FAST channels to audiences in the United States and potentially in additional territories, all without any authorization, license, or consent from Aurelius.

CipherTrace Analytics has confirmed, through analysis of publicly accessible streaming data, metadata fingerprinting, and content identification technology, that Aurelius-owned titles — including titles from the Meridian franchise, the Iron Compass series, the Thornfield catalog, and numerous additional works identified in Exhibit A — are currently available for streaming on BrightLoop's FAST channels. The unauthorized exploitation has been ongoing since approximately April 1, 2024 — a period of approximately 22 months through January 31, 2026 — and continues unabated as of the date of this letter.

At no point during this 22-month period has BrightLoop contacted Aurelius, AMA, or any authorized representative of Aurelius to verify the legitimacy of the rights purportedly conveyed to it by StreamNow, to confirm StreamNow's authority to sublicense the content, or to request or obtain a direct license from the actual rights holder. BrightLoop's failure to conduct even the most basic due diligence regarding the provenance and authorization of the content it distributes is deeply troubling and is directly relevant to the question of BrightLoop's culpability and the willfulness of its infringement, as discussed further below.

II. LEGAL BASIS

A. Copyright Infringement Under 17 U.S.C. §§ 106 and 501

As the exclusive owner of the United States copyrights in the 217 audiovisual works at issue, Aurelius holds the exclusive rights set forth in Section 106 of the Copyright Act, 17 U.S.C. § 106, including without limitation:

(1) The exclusive right to reproduce the copyrighted works in copies or phonorecords (17 U.S.C. § 106(1));

(3) The exclusive right to distribute copies or phonorecords of the copyrighted works to the public by sale or other transfer of ownership, or by rental, lease, or lending (17 U.S.C. § 106(3)); and

(4) The exclusive right to perform the copyrighted works publicly, in the case of literary, musical, dramatic, and choreographic works, pantomimes, and motion pictures and other audiovisual works (17 U.S.C. § 106(4)).

BrightLoop's ongoing distribution and public performance of these 217 works through its FAST channels, without any authorization from Aurelius, constitutes direct copyright infringement under 17 U.S.C. § 501(a), which provides that "[a]nyone who violates any of the exclusive rights of the copyright owner as provided by sections 106 through 122 … is an infringer of the copyright." BrightLoop has violated at least three of Aurelius's exclusive rights — reproduction (by copying and storing the works on its servers and content delivery networks), distribution (by making the works available to its subscribers and users through its FAST channels), and public performance (by streaming and transmitting the works to members of the public).

BrightLoop cannot claim shelter under any valid license or sublicense. It is black-letter copyright law that a sublicensee can obtain no greater rights than those held by the sublicensor. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002) ("One who acquires rights under a license from a licensee—i.e., a sublicensee—acquires no greater rights than those held by the licensee."); Gilliam v. Am. Broad. Cos., 538 F.2d 14, 21 (2d Cir. 1976). Since StreamNow held no valid rights in the Aurelius content — having purportedly obtained them from MDD, which had absolutely no authority from Aurelius — StreamNow could convey no rights to BrightLoop. BrightLoop's purported sublicense is therefore a legal nullity, and BrightLoop's exploitation of Aurelius content is and has been entirely unauthorized from inception.

Nor does BrightLoop qualify for any safe harbor under the Digital Millennium Copyright Act, 17 U.S.C. § 512, as BrightLoop is not merely a passive intermediary or hosting service but rather actively selects, curates, programs, and distributes the content at issue through its own branded FAST channels. BrightLoop exercises editorial control over the content it streams and derives direct financial benefit from the infringing activity in the form of advertising revenue generated by the streaming of Aurelius content to BrightLoop's viewers.

B. Willfulness and Enhanced Damages Exposure

To the extent that BrightLoop continues to distribute, reproduce, or publicly perform any Aurelius-owned content after receipt of this letter, any such continued infringement will be deemed willful under the Copyright Act. Upon receipt of this letter, BrightLoop can no longer plausibly claim ignorance of the fact that its exploitation of Aurelius content is unauthorized and constitutes copyright infringement.

Willful infringement exposes BrightLoop to enhanced statutory damages of up to $150,000 per work infringed under 17 U.S.C. § 504(c)(2). Given that 217 separate copyrighted works are at issue, BrightLoop's maximum statutory damages exposure for willful infringement is $32,550,000 (217 works × $150,000 per work). In addition, willful infringement supports an award of full attorneys' fees and costs to the prevailing party under 17 U.S.C. § 505, which Aurelius will seek in any litigation arising from BrightLoop's infringement.

The foregoing statutory damages figures are in addition to, and do not limit, Aurelius's right to elect to recover actual damages and infringer's profits under 17 U.S.C. § 504(b), should that measure prove more favorable.

C. Scope of Liability

BrightLoop's potential financial exposure in this matter is substantial. Calderwood & Harkness has retained Hargrove Economic Consulting Group, LLC, a leading economic and damages consulting firm, led by Dr. Elena Vasquez, to prepare a comprehensive economic analysis of the damages attributable to the unauthorized exploitation of the 217 Aurelius titles across the entire unauthorized distribution chain. Dr. Vasquez's preliminary analysis estimates aggregate net recoverable damages across all infringers at approximately $41.3 million, taking into account lost licensing fees, actual damages, and disgorgement of infringer's profits.

Within that aggregate damages estimate, Calderwood & Harkness's investigation has determined that StreamNow received an estimated $6.5 million in sublicensing fees from FAST channel operators — including BrightLoop — for content bundles containing Aurelius-owned titles during the relevant period. BrightLoop's proportionate share of these fees, and any advertising revenue and other monetization derived from the unauthorized streaming of Aurelius content, are subject to disgorgement and recovery by Aurelius. Aurelius intends to pursue recovery of BrightLoop's proportionate share of the overall damages in full.

III. DEMANDS

In light of the foregoing, Aurelius hereby makes the following demands:

Demand 1: Immediate Cessation and Removal

BrightLoop must immediately — meaning within twenty-four (24) hours of receipt of this letter — cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned audiovisual content across all of BrightLoop's FAST channels and any other platforms, services, applications, websites, or distribution mechanisms operated by, controlled by, or affiliated with BrightLoop, in all territories.

BrightLoop must promptly remove and permanently delete all copies of the 217 Aurelius titles identified in Exhibit A (and any portions, clips, excerpts, trailers, promotional materials, or derivative versions thereof) from BrightLoop's servers, content delivery networks ("CDNs"), caches, edge servers, cloud storage environments, local storage systems, backup systems, disaster recovery systems, and any other storage media or systems in which such content may reside. This removal and deletion obligation encompasses all territories in which BrightLoop operates or in which BrightLoop's FAST channels are accessible to consumers.

BrightLoop must further ensure that no Aurelius-owned content remains accessible to any BrightLoop user, subscriber, or viewer through any on-demand, linear, or other playback mechanism following completion of the takedown.

Demand 2: Confirmation of Takedown

BrightLoop must provide written confirmation to Calderwood & Harkness LLP within ten (10) business days of receipt of this letter that:

(a) All Aurelius-owned content has been removed from all of BrightLoop's FAST channels, platforms, servers, CDNs, caches, and storage systems;

(b) All unauthorized distribution, reproduction, and public performance of Aurelius content has permanently ceased; and

(c) BrightLoop has taken all necessary technical and operational steps to ensure that no Aurelius content will be re-ingested, re-distributed, or re-streamed through BrightLoop's systems in the future.

Such written confirmation must be addressed to:

Wendy Schultz Senior Associate, intellectual Property Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067

Email: wschultz@calderwoodharkness.com

The written confirmation should include a detailed description of the specific steps taken by BrightLoop to identify and remove all Aurelius content from its systems, including any technical verification procedures employed (e.g., content fingerprinting, metadata searches, hash-value comparisons, manual review) to ensure completeness of the removal.

Demand 3: Preservation of Records

BrightLoop must immediately implement a litigation hold and preserve all documents and electronically stored information ("ESI") relating to the matters described in this letter, including without limitation:

(a) All documents, data, and records relating to BrightLoop's receipt, ingestion, storage, encoding, transcoding, distribution, streaming, and public performance of any Aurelius-owned content;

(b) All agreements, contracts, amendments, schedules, exhibits, term sheets, deal memos, correspondence, and communications between BrightLoop and StreamNow Holdings, Inc., including without limitation any sublicense agreements, content delivery agreements, content schedules, title lists, financial terms, payment records, invoices, and statements of account;

(c) All agreements, correspondence, communications, and records referencing or relating to Meridian Digital Distributors, LLC or Franklin Ogilvie;

(d) All viewership data, traffic data, audience metrics, impressions, unique viewers, viewing hours, completion rates, and any other analytics or audience measurement data relating to any Aurelius content streamed, distributed, or performed on BrightLoop's FAST channels;

(e) All revenue data, financial records, and accounting information — including advertising revenue, CPM rates, ad insertion data, programmatic advertising records, licensing fees, revenue-sharing payments, and any other monetization data — attributable to or associated with the streaming, distribution, or performance of Aurelius content on BrightLoop's platforms;

(f) All internal communications — including emails, text messages, instant messages (on platforms including but not limited to Meridian Solutions, Northgate Data Systems, and similar applications), memoranda, meeting notes, calendar entries, and presentations — relating to the acquisition, licensing, curation, programming, scheduling, or distribution of Aurelius content or content obtained from StreamNow; and

(g) All due diligence materials, rights verification records, chain-of-title documentation, and compliance records relating to BrightLoop's assessment of the rights purportedly granted by StreamNow.

This preservation obligation extends to all backup systems, archived materials, disaster recovery systems, cloud-based storage, personal devices used for business purposes, and all associated metadata (including creation dates, modification dates, access logs, and author information).

BrightLoop is hereby placed on notice that failure to preserve relevant records may result in spoliation sanctions, including adverse inference instructions, in any subsequent litigation. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212, 218 (S.D.N.Y. 2003) (imposing sanctions for failure to preserve relevant evidence after litigation was reasonably anticipated); Camberwell & Co. v. Northgate & Co. Elecs. Co., 881 F. Supp. 2d 1132 (N.D. Cal. 2012). BrightLoop's duty to preserve evidence attached no later than the date of this letter.

Demand 4: Accounting

BrightLoop must provide a full and complete accounting of all revenues generated from the distribution, public performance, or other exploitation of any and all Aurelius-owned content. This accounting must be broken down by:

(a) Individual title (identifying each Aurelius work by name, and cross-referenced to Exhibit A);

(b) Time period (monthly, from the date of first distribution through the present);

(d) Revenue source (distinguishing among advertising revenue, licensing fees, revenue-sharing payments, and any other form of monetization).

This accounting must be provided to Calderwood & Harkness LLP, at the address set forth above, within thirty (30) calendar days of BrightLoop's receipt of this letter. Aurelius reserves the right to audit and verify the accuracy and completeness of any accounting provided by BrightLoop through its own forensic accountants and economic consultants.

IV. RESERVATION OF RIGHTS

Aurelius expressly reserves all of its rights, remedies, claims, and defenses, at law and in equity, including but not limited to the right to seek:

(a) Actual damages and infringer's profits under 17 U.S.C. § 504(b);

(b) Statutory damages, including enhanced statutory damages for willful infringement, under 17 U.S.C. § 504(c);

(d) Impoundment and disposition of infringing articles under 17 U.S.C. § 503;

(e) An award of full costs and reasonable attorneys' fees under 17 U.S.C. § 505;

(f) Any and all remedies available under the common law and the statutory law of the State of California, including without limitation claims for unfair business practices under California Business and Professions Code § 17200 et seq.; and

(g) Any and all other remedies to which Aurelius may be entitled under applicable federal, state, or foreign law.

Nothing in this letter shall be construed as a waiver or limitation of any claim, right, remedy, or defense available to Aurelius, whether or not expressly referenced herein. Aurelius's decision to make the demands set forth in this letter does not constitute an election of remedies, and Aurelius's willingness to allow BrightLoop a limited period to comply with these demands does not constitute a waiver of Aurelius's right to pursue claims for past infringement. No failure or delay by Aurelius in exercising any right shall operate as a waiver thereof, and no single or partial exercise of any right shall preclude any other or further exercise thereof or the exercise of any other right.

Aurelius further reserves the right to name BrightLoop Media, LLC as a defendant in litigation that Aurelius is currently preparing for filing in the United States District Court for the Central District of California, should BrightLoop fail to comply fully and timely with the demands set forth in this letter. Aurelius is prepared to seek emergency injunctive relief, including a temporary restraining order and preliminary injunction, to halt BrightLoop's unauthorized distribution and performance of Aurelius content in the event that BrightLoop does not effectuate the requested takedown voluntarily.

V. PARALLEL ENFORCEMENT ACTIONS

Please be advised that substantially similar takedown demands are being served simultaneously on the following parties:

• StreamNow Holdings, Inc., via its General Counsel, Tobias Rennert, at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010;

• Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager), at 8912 Burton Way, Suite 200, Beverly Hills, California 90211;

• Brindoval Channel Networks, Inc., at its principal offices in Dallas, Texas;

• Velvet Stream Partners, LP, at its principal offices in Toronto, Ontario, Canada; and

• Pacific Lantern Digital Pty Ltd, at its principal offices in Sydney, New South Wales, Australia.

Aurelius is pursuing coordinated enforcement across the entire unauthorized distribution chain and is prepared to file suit against all parties responsible for the infringement of its intellectual property rights.

VI. INSTRUCTION TO SEEK LEGAL COUNSEL

BrightLoop is strongly urged to consult immediately with its own legal counsel regarding its obligations under this letter, its potential liability for copyright infringement, and the potential consequences of non-compliance with the demands set forth herein. The issues presented in this letter are complex and carry significant financial and legal exposure for BrightLoop.

BrightLoop's counsel may contact the undersigned, Wendy Schultz, Senior Associate, or Marcus Delgado, Partner, at Calderwood & Harkness LLP, at the address, telephone number, and email address set forth above, to discuss this matter and coordinate BrightLoop's response.

VII. CONCLUSION

Aurelius demands that BrightLoop respond to and comply fully with each of the demands set forth in this letter within ten (10) business days of BrightLoop's receipt hereof. Aurelius intends to vigorously enforce its intellectual property rights and will not hesitate to pursue all available legal remedies — including the immediate commencement of federal litigation, emergency injunctive relief, and the recovery of substantial damages — if BrightLoop does not comply with the foregoing demands fully and in a timely manner.

We trust that BrightLoop will act promptly and in good faith to resolve this matter without the need for litigation. Time is of the essence.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Wendy Schultz Senior Associate, intellectual Property

Admitted in California (SBN 342917) Direct: (310) 556-7243

Email: wschultz@calderwoodharkness.com

cc: (via email and U.S. Mail)

Marcus Delgado, Partner, intellectual Property, Calderwood & Harkness LLP

Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC, 45 Clarewood Place, London W1K 6TH, United Kingdom

Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Global Media Group PLC, 45 Clarewood Place, London W1K 6TH, United Kingdom

Enclosures:

Exhibit A — Schedule of 217 Aurelius-Owned Audiovisual Works Subject to This Demand (Comprehensive Title List, Including U.S. Copyright Registration Numbers, Production Years, and Format Designations)

[Note: Exhibit A is enclosed as a separate schedule to this letter and comprises 14 pages listing all 217 works. A copy is also available in electronic format upon request to the undersigned.]

PRIVILEGED AND CONFIDENTIAL
CALDERWOOD & HARKNESS LLP Attorneys at Law
1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-7200 Facsimile: (310) 556-7201
600 Lexington Avenue, 38th Floor New York, New York 10022 Telephone: (212) 848-4500 Facsimile: (212) 848-4501
Wendy Schultz Senior Associate, intellectual Property Direct: (310) 556-7243
Email: wschultz@calderwoodharkness.com
March 14, 2026
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND ELECTRONIC MAIL
BrightLoop Media, LLC
Attn: General Counsel / Managing Member
2700 Biscayne Boulevard, Suite 900 Miami, Florida 33137
Re: Unauthorized Distribution and Public Performance of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Takedown and Preservation of Records
Matter Reference: 1017-00003
Dear General Counsel or Managing Member:
This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated in England and Wales under the Companies Act 2006 (Companies House Registration No. 08724561), with its registered office and principal place of business at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius operates in the United States through its wholly-owned subsidiary, Aurelius Media Americas, Inc. ("AMA"), a corporation organized and existing under the laws of the State of Delaware, with offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. As you may be aware, Aurelius is a major international media and entertainment conglomerate with fiscal year 2025 consolidated revenue of approximately £1.87 billion (approximately $2.36 billion USD), whose ordinary shares are admitted to trading on the AIM market of the London Stock Exchange under the ticker symbol AGLM. Aurelius and its affiliated entities own and control a content library encompassing more than 4,200 film and television titles, including numerous high-profile theatrical franchises, award-winning television series, and critically acclaimed catalog titles distributed worldwide.
We write to you on behalf of Aurelius to make a formal demand that BrightLoop Media, LLC ("BrightLoop") immediately cease all unauthorized reproduction, distribution, and public performance of Aurelius-owned copyrighted audiovisual content that is currently being exploited, without any authorization whatsoever from Aurelius, through BrightLoop's Free Ad-Supported Streaming Television ("FAST") channels and any related platforms or distribution mechanisms. As detailed below, the content at issue was unlawfully sublicensed to BrightLoop by StreamNow Holdings, Inc. ("StreamNow"), a Delaware corporation (Secretary of State File No. 7291843) headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, which itself purported to obtain the content through a fraudulent and wholly unauthorized chain of distribution originating with an entity called Meridian Digital Distributors, LLC ("MDD"). Neither MDD nor StreamNow has ever possessed any license, sublicense, or distribution authority from Aurelius with respect to any Aurelius-owned content. Accordingly, BrightLoop's ongoing exploitation of this content constitutes direct copyright infringement under federal law, and Aurelius demands that BrightLoop take the immediate corrective actions described in this letter.
I. BACKGROUND AND FACTUAL SUMMARY
A. Aurelius's Content Ownership
Aurelius and its subsidiaries hold all relevant United States copyrights in a catalog of at least 217 audiovisual works — comprising 142 feature films and 75 television series (encompassing 1,038 individual episodes) — that are the subject of this demand. Of these 217 works, 189 have been the subject of timely registrations with the United States Copyright Office, and the remaining 28 titles have also been registered with the Copyright Office, ensuring that Aurelius is entitled to the full panoply of remedies available under the Copyright Act for infringement of all 217 works. A comprehensive listing of the 217 titles at issue is set forth in Exhibit A attached hereto.
The Aurelius content library at issue includes some of the most commercially and critically significant audiovisual properties in the international entertainment market. Key properties include, without limitation:
• The "Meridian" franchise, consisting of six theatrical feature films released between 2012 and 2024, with a combined worldwide theatrical gross of approximately $1.43 billion and substantial additional revenues from home entertainment, pay television, subscription video-on-demand ("SVOD"), and ancillary exploitation windows;
• The "Iron Compass" series, a four-season, 48-episode dramatic television series that averaged 9.2 million viewers per episode in the United Kingdom during its original broadcast run on Severin Enterprises, and which has been licensed for distribution in over 60 territories worldwide; and
• The "Thornfield" period drama catalog, comprising 12 separate titles (both feature-length productions and limited series) that have collectively been honored with seven British Academy of Film and Television Arts ("BAFTA") awards, three International Emmy Awards, and numerous additional nominations and accolades.
These properties, together with the remainder of the 217 works identified in Exhibit A, represent a significant portion of Aurelius's most valuable intellectual property assets. Aurelius has invested hundreds of millions of dollars in the development, production, marketing, and distribution of these works, and it manages and enforces its rights in this content aggressively and systematically across all distribution platforms and territories.
Aurelius has confirmed its unbroken chain of title for all 217 works through a comprehensive chain-of-title analysis and United States Copyright Office records search completed by Lexington IP Services, Inc., an independent title search and clearance firm, on January 22, 2026. That analysis confirmed that Aurelius (directly or through its subsidiaries, with all rights having been properly assigned and recorded) is the sole and exclusive owner of all U.S. copyrights in each of the 217 works, including without limitation the exclusive rights of reproduction, distribution, and public performance under 17 U.S.C. § 106. No license, sublicense, assignment, or other grant of rights in any of these works has been made to MDD, StreamNow, BrightLoop, or any other party in the unauthorized distribution chain described below.
B. The Unauthorized Sublicensing Chain
Calderwood & Harkness's investigation has uncovered the following facts regarding the unauthorized sublicensing chain through which BrightLoop came to exploit Aurelius-owned content without authorization.
StreamNow Holdings, Inc. operates what it describes as a "super-aggregator" streaming platform that bundles content from multiple distributors and rights holders into subscription-based and ad-supported tiers, currently available to consumers in approximately 14 countries across North America, Europe, Latin America, and the Asia-Pacific region. StreamNow purported to obtain rights to the 217 Aurelius titles at issue through a document styled as a "Content Distribution Agreement" allegedly executed on or about March 15, 2024, with Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with its principal address listed at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.
MDD is controlled by Franklin Ogilvie, who is its sole member and manager. Mr. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc., where he was employed from approximately 2017 through June 30, 2021. Mr. Ogilvie's employment with AMA was terminated on June 30, 2021, following an internal investigation conducted by AMA's Legal and Compliance departments, which uncovered evidence of unauthorized access to and misuse of Aurelius's proprietary content management systems, including unauthorized download and export of content metadata, technical specifications, and distribution key files. In connection with his departure, Mr. Ogilvie executed a separation agreement and general release dated June 30, 2021, which included, among other provisions, a non-competition covenant, a non-solicitation covenant, a comprehensive confidentiality obligation, and an explicit, unambiguous prohibition on the use, distribution, sublicensing, or other exploitation of any Aurelius intellectual property, trade secrets, or proprietary information following termination.
Despite these obligations, Mr. Ogilvie formed MDD and subsequently purported to license Aurelius-owned content to StreamNow — content over which neither he nor MDD has ever had any authority, license, or right of any kind. To be absolutely clear: Aurelius has never granted MDD any license, sublicense, distribution agreement, or any other form of authorization to reproduce, distribute, publicly perform, or otherwise exploit any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius in any capacity.
Consequently, StreamNow never acquired valid rights to any of the Aurelius content purportedly licensed to it by MDD. The March 15, 2024 Content Distribution Agreement between MDD and StreamNow — to the extent it purports to grant rights in Aurelius-owned content — is void and of no force or effect, as MDD had no rights to grant. StreamNow therefore had no authority to sublicense any Aurelius-owned content to BrightLoop or to any other party, and any purported sublicense from StreamNow to BrightLoop conveying rights in Aurelius content is similarly void and without legal effect.
C. BrightLoop's Receipt and Exploitation of Infringing Content
Calderwood & Harkness's investigation, including a comprehensive digital forensic analysis conducted by CipherTrace Analytics, LLC — a nationally recognized digital media forensics firm, under the direction of Dr. Nathan Frey, Director of Digital Media Forensics — has confirmed the following:
StreamNow sublicensed content bundles containing Aurelius-owned titles to BrightLoop Media, LLC, among other FAST channel operators. BrightLoop ingested these content bundles, integrated the Aurelius titles into its FAST channel programming, and has been and continues to distribute and publicly perform Aurelius's copyrighted audiovisual works through its FAST channels to audiences in the United States and potentially in additional territories, all without any authorization, license, or consent from Aurelius.
CipherTrace Analytics has confirmed, through analysis of publicly accessible streaming data, metadata fingerprinting, and content identification technology, that Aurelius-owned titles — including titles from the Meridian franchise, the Iron Compass series, the Thornfield catalog, and numerous additional works identified in Exhibit A — are currently available for streaming on BrightLoop's FAST channels. The unauthorized exploitation has been ongoing since approximately April 1, 2024 — a period of approximately 22 months through January 31, 2026 — and continues unabated as of the date of this letter.
At no point during this 22-month period has BrightLoop contacted Aurelius, AMA, or any authorized representative of Aurelius to verify the legitimacy of the rights purportedly conveyed to it by StreamNow, to confirm StreamNow's authority to sublicense the content, or to request or obtain a direct license from the actual rights holder. BrightLoop's failure to conduct even the most basic due diligence regarding the provenance and authorization of the content it distributes is deeply troubling and is directly relevant to the question of BrightLoop's culpability and the willfulness of its infringement, as discussed further below.
II. LEGAL BASIS
A. Copyright Infringement Under 17 U.S.C. §§ 106 and 501
As the exclusive owner of the United States copyrights in the 217 audiovisual works at issue, Aurelius holds the exclusive rights set forth in Section 106 of the Copyright Act, 17 U.S.C. § 106, including without limitation:
(1) The exclusive right to reproduce the copyrighted works in copies or phonorecords (17 U.S.C. § 106(1));
(3) The exclusive right to distribute copies or phonorecords of the copyrighted works to the public by sale or other transfer of ownership, or by rental, lease, or lending (17 U.S.C. § 106(3)); and
(4) The exclusive right to perform the copyrighted works publicly, in the case of literary, musical, dramatic, and choreographic works, pantomimes, and motion pictures and other audiovisual works (17 U.S.C. § 106(4)).
BrightLoop's ongoing distribution and public performance of these 217 works through its FAST channels, without any authorization from Aurelius, constitutes direct copyright infringement under 17 U.S.C. § 501(a), which provides that "[a]nyone who violates any of the exclusive rights of the copyright owner as provided by sections 106 through 122 … is an infringer of the copyright." BrightLoop has violated at least three of Aurelius's exclusive rights — reproduction (by copying and storing the works on its servers and content delivery networks), distribution (by making the works available to its subscribers and users through its FAST channels), and public performance (by streaming and transmitting the works to members of the public).
BrightLoop cannot claim shelter under any valid license or sublicense. It is black-letter copyright law that a sublicensee can obtain no greater rights than those held by the sublicensor. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002) ("One who acquires rights under a license from a licensee—i.e., a sublicensee—acquires no greater rights than those held by the licensee."); Gilliam v. Am. Broad. Cos., 538 F.2d 14, 21 (2d Cir. 1976). Since StreamNow held no valid rights in the Aurelius content — having purportedly obtained them from MDD, which had absolutely no authority from Aurelius — StreamNow could convey no rights to BrightLoop. BrightLoop's purported sublicense is therefore a legal nullity, and BrightLoop's exploitation of Aurelius content is and has been entirely unauthorized from inception.
Nor does BrightLoop qualify for any safe harbor under the Digital Millennium Copyright Act, 17 U.S.C. § 512, as BrightLoop is not merely a passive intermediary or hosting service but rather actively selects, curates, programs, and distributes the content at issue through its own branded FAST channels. BrightLoop exercises editorial control over the content it streams and derives direct financial benefit from the infringing activity in the form of advertising revenue generated by the streaming of Aurelius content to BrightLoop's viewers.
B. Willfulness and Enhanced Damages Exposure
To the extent that BrightLoop continues to distribute, reproduce, or publicly perform any Aurelius-owned content after receipt of this letter, any such continued infringement will be deemed willful under the Copyright Act. Upon receipt of this letter, BrightLoop can no longer plausibly claim ignorance of the fact that its exploitation of Aurelius content is unauthorized and constitutes copyright infringement.
Willful infringement exposes BrightLoop to enhanced statutory damages of up to $150,000 per work infringed under 17 U.S.C. § 504(c)(2). Given that 217 separate copyrighted works are at issue, BrightLoop's maximum statutory damages exposure for willful infringement is $32,550,000 (217 works × $150,000 per work). In addition, willful infringement supports an award of full attorneys' fees and costs to the prevailing party under 17 U.S.C. § 505, which Aurelius will seek in any litigation arising from BrightLoop's infringement.
The foregoing statutory damages figures are in addition to, and do not limit, Aurelius's right to elect to recover actual damages and infringer's profits under 17 U.S.C. § 504(b), should that measure prove more favorable.
C. Scope of Liability
BrightLoop's potential financial exposure in this matter is substantial. Calderwood & Harkness has retained Hargrove Economic Consulting Group, LLC, a leading economic and damages consulting firm, led by Dr. Elena Vasquez, to prepare a comprehensive economic analysis of the damages attributable to the unauthorized exploitation of the 217 Aurelius titles across the entire unauthorized distribution chain. Dr. Vasquez's preliminary analysis estimates aggregate net recoverable damages across all infringers at approximately $41.3 million, taking into account lost licensing fees, actual damages, and disgorgement of infringer's profits.
Within that aggregate damages estimate, Calderwood & Harkness's investigation has determined that StreamNow received an estimated $6.5 million in sublicensing fees from FAST channel operators — including BrightLoop — for content bundles containing Aurelius-owned titles during the relevant period. BrightLoop's proportionate share of these fees, and any advertising revenue and other monetization derived from the unauthorized streaming of Aurelius content, are subject to disgorgement and recovery by Aurelius. Aurelius intends to pursue recovery of BrightLoop's proportionate share of the overall damages in full.
III. DEMANDS
In light of the foregoing, Aurelius hereby makes the following demands:
Demand 1: Immediate Cessation and Removal
BrightLoop must immediately — meaning within twenty-four (24) hours of receipt of this letter — cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned audiovisual content across all of BrightLoop's FAST channels and any other platforms, services, applications, websites, or distribution mechanisms operated by, controlled by, or affiliated with BrightLoop, in all territories.
BrightLoop must promptly remove and permanently delete all copies of the 217 Aurelius titles identified in Exhibit A (and any portions, clips, excerpts, trailers, promotional materials, or derivative versions thereof) from BrightLoop's servers, content delivery networks ("CDNs"), caches, edge servers, cloud storage environments, local storage systems, backup systems, disaster recovery systems, and any other storage media or systems in which such content may reside. This removal and deletion obligation encompasses all territories in which BrightLoop operates or in which BrightLoop's FAST channels are accessible to consumers.
BrightLoop must further ensure that no Aurelius-owned content remains accessible to any BrightLoop user, subscriber, or viewer through any on-demand, linear, or other playback mechanism following completion of the takedown.
Demand 2: Confirmation of Takedown
BrightLoop must provide written confirmation to Calderwood & Harkness LLP within ten (10) business days of receipt of this letter that:
(a) All Aurelius-owned content has been removed from all of BrightLoop's FAST channels, platforms, servers, CDNs, caches, and storage systems;
(b) All unauthorized distribution, reproduction, and public performance of Aurelius content has permanently ceased; and
(c) BrightLoop has taken all necessary technical and operational steps to ensure that no Aurelius content will be re-ingested, re-distributed, or re-streamed through BrightLoop's systems in the future.
Such written confirmation must be addressed to:
Wendy Schultz Senior Associate, intellectual Property Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Email: wschultz@calderwoodharkness.com
The written confirmation should include a detailed description of the specific steps taken by BrightLoop to identify and remove all Aurelius content from its systems, including any technical verification procedures employed (e.g., content fingerprinting, metadata searches, hash-value comparisons, manual review) to ensure completeness of the removal.
Demand 3: Preservation of Records
BrightLoop must immediately implement a litigation hold and preserve all documents and electronically stored information ("ESI") relating to the matters described in this letter, including without limitation:
(a) All documents, data, and records relating to BrightLoop's receipt, ingestion, storage, encoding, transcoding, distribution, streaming, and public performance of any Aurelius-owned content;
(b) All agreements, contracts, amendments, schedules, exhibits, term sheets, deal memos, correspondence, and communications between BrightLoop and StreamNow Holdings, Inc., including without limitation any sublicense agreements, content delivery agreements, content schedules, title lists, financial terms, payment records, invoices, and statements of account;
(c) All agreements, correspondence, communications, and records referencing or relating to Meridian Digital Distributors, LLC or Franklin Ogilvie;
(d) All viewership data, traffic data, audience metrics, impressions, unique viewers, viewing hours, completion rates, and any other analytics or audience measurement data relating to any Aurelius content streamed, distributed, or performed on BrightLoop's FAST channels;
(e) All revenue data, financial records, and accounting information — including advertising revenue, CPM rates, ad insertion data, programmatic advertising records, licensing fees, revenue-sharing payments, and any other monetization data — attributable to or associated with the streaming, distribution, or performance of Aurelius content on BrightLoop's platforms;
(f) All internal communications — including emails, text messages, instant messages (on platforms including but not limited to Meridian Solutions, Northgate Data Systems, and similar applications), memoranda, meeting notes, calendar entries, and presentations — relating to the acquisition, licensing, curation, programming, scheduling, or distribution of Aurelius content or content obtained from StreamNow; and
(g) All due diligence materials, rights verification records, chain-of-title documentation, and compliance records relating to BrightLoop's assessment of the rights purportedly granted by StreamNow.
This preservation obligation extends to all backup systems, archived materials, disaster recovery systems, cloud-based storage, personal devices used for business purposes, and all associated metadata (including creation dates, modification dates, access logs, and author information).
BrightLoop is hereby placed on notice that failure to preserve relevant records may result in spoliation sanctions, including adverse inference instructions, in any subsequent litigation. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212, 218 (S.D.N.Y. 2003) (imposing sanctions for failure to preserve relevant evidence after litigation was reasonably anticipated); Camberwell & Co. v. Northgate & Co. Elecs. Co., 881 F. Supp. 2d 1132 (N.D. Cal. 2012). BrightLoop's duty to preserve evidence attached no later than the date of this letter.
Demand 4: Accounting
BrightLoop must provide a full and complete accounting of all revenues generated from the distribution, public performance, or other exploitation of any and all Aurelius-owned content. This accounting must be broken down by:
(a) Individual title (identifying each Aurelius work by name, and cross-referenced to Exhibit A);
(b) Time period (monthly, from the date of first distribution through the present);
(c) Territory (identifying all countries and regions in which Aurelius content was distributed or made available); and
(d) Revenue source (distinguishing among advertising revenue, licensing fees, revenue-sharing payments, and any other form of monetization).
This accounting must be provided to Calderwood & Harkness LLP, at the address set forth above, within thirty (30) calendar days of BrightLoop's receipt of this letter. Aurelius reserves the right to audit and verify the accuracy and completeness of any accounting provided by BrightLoop through its own forensic accountants and economic consultants.
IV. RESERVATION OF RIGHTS
Aurelius expressly reserves all of its rights, remedies, claims, and defenses, at law and in equity, including but not limited to the right to seek:
(a) Actual damages and infringer's profits under 17 U.S.C. § 504(b);
(b) Statutory damages, including enhanced statutory damages for willful infringement, under 17 U.S.C. § 504(c);
(c) Temporary, preliminary, and permanent injunctive relief under 17 U.S.C. § 502;
(d) Impoundment and disposition of infringing articles under 17 U.S.C. § 503;
(e) An award of full costs and reasonable attorneys' fees under 17 U.S.C. § 505;
(f) Any and all remedies available under the common law and the statutory law of the State of California, including without limitation claims for unfair business practices under California Business and Professions Code § 17200 et seq.; and
(g) Any and all other remedies to which Aurelius may be entitled under applicable federal, state, or foreign law.
Nothing in this letter shall be construed as a waiver or limitation of any claim, right, remedy, or defense available to Aurelius, whether or not expressly referenced herein. Aurelius's decision to make the demands set forth in this letter does not constitute an election of remedies, and Aurelius's willingness to allow BrightLoop a limited period to comply with these demands does not constitute a waiver of Aurelius's right to pursue claims for past infringement. No failure or delay by Aurelius in exercising any right shall operate as a waiver thereof, and no single or partial exercise of any right shall preclude any other or further exercise thereof or the exercise of any other right.
Aurelius further reserves the right to name BrightLoop Media, LLC as a defendant in litigation that Aurelius is currently preparing for filing in the United States District Court for the Central District of California, should BrightLoop fail to comply fully and timely with the demands set forth in this letter. Aurelius is prepared to seek emergency injunctive relief, including a temporary restraining order and preliminary injunction, to halt BrightLoop's unauthorized distribution and performance of Aurelius content in the event that BrightLoop does not effectuate the requested takedown voluntarily.
V. PARALLEL ENFORCEMENT ACTIONS
Please be advised that substantially similar takedown demands are being served simultaneously on the following parties:
• StreamNow Holdings, Inc., via its General Counsel, Tobias Rennert, at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010;
• Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager), at 8912 Burton Way, Suite 200, Beverly Hills, California 90211;
• Brindoval Channel Networks, Inc., at its principal offices in Dallas, Texas;
• Velvet Stream Partners, LP, at its principal offices in Toronto, Ontario, Canada; and
• Pacific Lantern Digital Pty Ltd, at its principal offices in Sydney, New South Wales, Australia.
Aurelius is pursuing coordinated enforcement across the entire unauthorized distribution chain and is prepared to file suit against all parties responsible for the infringement of its intellectual property rights.
VI. INSTRUCTION TO SEEK LEGAL COUNSEL
BrightLoop is strongly urged to consult immediately with its own legal counsel regarding its obligations under this letter, its potential liability for copyright infringement, and the potential consequences of non-compliance with the demands set forth herein. The issues presented in this letter are complex and carry significant financial and legal exposure for BrightLoop.
BrightLoop's counsel may contact the undersigned, Wendy Schultz, Senior Associate, or Marcus Delgado, Partner, at Calderwood & Harkness LLP, at the address, telephone number, and email address set forth above, to discuss this matter and coordinate BrightLoop's response.
VII. CONCLUSION
Aurelius demands that BrightLoop respond to and comply fully with each of the demands set forth in this letter within ten (10) business days of BrightLoop's receipt hereof. Aurelius intends to vigorously enforce its intellectual property rights and will not hesitate to pursue all available legal remedies — including the immediate commencement of federal litigation, emergency injunctive relief, and the recovery of substantial damages — if BrightLoop does not comply with the foregoing demands fully and in a timely manner.
We trust that BrightLoop will act promptly and in good faith to resolve this matter without the need for litigation. Time is of the essence.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Wendy Schultz Senior Associate, intellectual Property
Admitted in California (SBN 342917) Direct: (310) 556-7243
Email: wschultz@calderwoodharkness.com
cc: (via email and U.S. Mail)
Marcus Delgado, Partner, intellectual Property, Calderwood & Harkness LLP
Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC, 45 Clarewood Place, London W1K 6TH, United Kingdom
Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Global Media Group PLC, 45 Clarewood Place, London W1K 6TH, United Kingdom
Enclosures:
Exhibit A — Schedule of 217 Aurelius-Owned Audiovisual Works Subject to This Demand (Comprehensive Title List, Including U.S. Copyright Registration Numbers, Production Years, and Format Designations)
[Note: Exhibit A is enclosed as a separate schedule to this letter and comprises 14 pages listing all 217 works. A copy is also available in electronic format upon request to the undersigned.]

PRIVILEGED AND CONFIDENTIAL

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND ELECTRONIC MAIL

I. BACKGROUND AND FACTUAL SUMMARY

II. LEGAL BASIS

III. DEMANDS

IV. RESERVATION OF RIGHTS

V. PARALLEL ENFORCEMENT ACTIONS

VI. INSTRUCTION TO SEEK LEGAL COUNSEL

VII. CONCLUSION

CALDERWOOD & HARKNESS LLP

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