takedown-demand-crestview.docx

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

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CALDERWOOD & HARKNESS LLP Attorneys at Law 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200 Facsimile: (310) 555-7201 www.calderwoodharkness.com

March 14, 2026

VIA FEDEX OVERNIGHT DELIVERY AND EMAIL

CONFIDENTIAL — URGENT

Brindoval Channel Networks, Inc. 2700 Commerce Street, Suite 1400 Dallas, Texas 75201

Attention: General Counsel / Legal Department

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

Our Matter No. 1017-00003

To the General Counsel:

I. Introduction and Identification of Client

This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated in England and Wales (Companies House Registration No. 08724561), with its principal executive offices located 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.

Aurelius is a leading global media and entertainment conglomerate with fiscal year 2025 revenues of approximately £1.87 billion (approximately $2.36 billion at current exchange rates). Aurelius is listed on the London Stock Exchange (AIM: AGLM) and is one of the largest independent content libraries in the world. Aurelius owns and controls a comprehensive content library of over 4,200 film and television titles, spanning multiple genres and decades of production. Among its internationally recognized properties are the "Meridian" franchise (comprising six theatrical feature films with a combined global box office of $1.43 billion), the "Iron Compass" series (four seasons, forty-eight episodes, averaging 9.2 million viewers per episode in the United Kingdom), and the "Thornfield" period drama catalog (twelve titles, recipient of seven BAFTA awards). These properties, along with the remainder of Aurelius's extensive content library, represent substantial creative, financial, and strategic investments that Aurelius vigilantly protects.

We write to you on behalf of Aurelius and AMA concerning the unauthorized distribution of copyrighted audiovisual works owned by Aurelius through streaming channels operated or controlled by Brindoval Channel Networks, Inc. ("Brindoval"). The facts described in this letter constitute serious violations of Aurelius's exclusive rights under the United States Copyright Act, 17 U.S.C. §§ 101 et seq., and we demand immediate corrective action as set forth below.

II. Nature of the Infringement and Brindoval's Involvement

Through ongoing monitoring, forensic investigation, and industry intelligence, Aurelius has determined that Brindoval is currently distributing, reproducing, and/or publicly performing copyrighted audiovisual works owned exclusively by Aurelius through one or more FAST (Free Ad-Supported Streaming Television) channels that Brindoval operates, controls, or otherwise makes available to the public. The infringing activity encompasses the unauthorized streaming, caching, reproduction, and public performance of Aurelius-owned content to end users across the United States and potentially in other territories.

The content at issue comprises at least 217 titles, consisting of 142 feature films and 75 television series comprising a total of 1,038 episodes, all of which are owned exclusively by Aurelius and/or Aurelius Media Americas, Inc. Valid United States Copyright Office registrations exist for each of these works, as detailed further in Section IV below. The affected titles include, but are not limited to, the following key franchises and properties from the Aurelius catalog:

• All six films in the "Meridian" franchise;

• All four seasons (forty-eight episodes) of the "Iron Compass" series;

• All twelve titles in the "Thornfield" period drama catalog; and

• Numerous additional feature films and television series from the broader Aurelius content library.

A representative list of the 217 affected titles is available upon request and will be provided as an attachment to this letter or under separate cover. We urge Brindoval to contact the undersigned promptly if it requires the complete title list to facilitate expeditious removal of all infringing content.

Based on the evidence gathered through Aurelius's investigation, including timestamped captures, metadata analysis, and platform monitoring, the unauthorized exploitation of Aurelius content on Brindoval's channels has been ongoing since approximately April 1, 2024, spanning a period of at least twenty-two (22) months through the date of this letter. The scope and duration of this unauthorized distribution are deeply concerning to our client and represent a substantial and continuing injury to Aurelius's exclusive rights and commercial interests.

III. Source of the Unauthorized Content — The StreamNow Sublicense

Upon thorough investigation, Aurelius has established that Brindoval obtained the Aurelius content through a sublicense from StreamNow Holdings, Inc. ("StreamNow"), a corporation organized under the laws of the State of Delaware (Secretary of State File No. 7291843), with its principal offices at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a streaming "super-aggregator" platform that bundles content from multiple sources and sublicenses assembled content bundles to third-party FAST channel operators, including Brindoval.

StreamNow purported to acquire rights to distribute Aurelius content through a "Content Distribution Agreement" allegedly executed on or about March 15, 2024, with an entity known as Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430), with a principal address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

Aurelius's investigation has revealed the following critical facts regarding MDD and the provenance of the purported rights:

(a) MDD's sole member and manager is Franklin Ogilvie, a former mid-level licensing manager at Aurelius Media Americas, Inc. Mr. Ogilvie's employment with AMA terminated on June 30, 2021, following an internal investigation that uncovered unauthorized access by Mr. Ogilvie to Aurelius's proprietary content management systems, including digital asset management platforms and rights databases.

(b) In connection with the termination of his employment, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, an explicit and unconditional prohibition on the use of any Aurelius intellectual property, including but not limited to copyrighted audiovisual works, trademarks, trade secrets, and proprietary business information. The separation agreement also contained non-compete and non-solicitation covenants restricting Mr. Ogilvie's activities in the media licensing and distribution sector.

(c) Notwithstanding these restrictions, Mr. Ogilvie subsequently formed MDD and, operating through that entity, purported to grant StreamNow distribution rights to the Aurelius content catalog — rights that Mr. Ogilvie and MDD never possessed and had no authority to grant.

We wish to make the following points absolutely clear:

Aurelius has never granted MDD, Franklin Ogilvie, StreamNow Holdings, Inc., or any other intermediary any license, sublicense, or distribution authority of any kind over any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius or any Aurelius affiliate. No individual or entity within the Aurelius corporate family has ever authorized, ratified, or acquiesced in any purported grant of rights by MDD or Mr. Ogilvie to any third party.

Consequently, StreamNow had no valid rights to sublicense Aurelius content to Brindoval or to any other party. The purported sublicense from StreamNow to Brindoval is derived from a chain of title that is fatally defective at its inception, as MDD and Mr. Ogilvie possessed no rights whatsoever to convey. It is a well-established principle of copyright law that a sublicensee's rights cannot exceed those of its sublicensor. Because StreamNow held no valid license from Aurelius, any sublicense purportedly granted by StreamNow to Brindoval is void and without legal effect and provides no defense to Brindoval's infringement of Aurelius's copyrights.

IV. Aurelius's Rights — Copyright Ownership and Registration

Aurelius and/or AMA are the exclusive owners of all copyrights in the 217 audiovisual works at issue, including all exclusive rights of reproduction, distribution, public performance, and display under Section 106 of the Copyright Act, 17 U.S.C. § 106. Aurelius's copyright ownership encompasses all formats, media, and distribution platforms, including without limitation theatrical, home video, television, cable, satellite, streaming, FAST, AVOD, SVOD, TVOD, and all other current and future forms of exploitation.

Of the 217 titles at issue, 189 titles have valid, timely United States Copyright Office registrations that were filed either within three months of first publication or prior to the commencement of the infringement. These timely registrations render all 189 titles eligible for the full range of remedies available under the Copyright Act, including:

• Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2); and

• Recovery of attorneys' fees and full costs under 17 U.S.C. § 505.

An additional 28 titles have valid United States Copyright Office registrations that, while confirming Aurelius's copyright ownership, post-date the commencement of the infringing activity. These 28 titles are eligible for recovery of actual damages sustained by Aurelius as well as the infringer's profits attributable to the infringement under 17 U.S.C. § 504(b).

The copyright registration status of all 217 titles has been independently verified by Lexington IP Services, Inc., a nationally recognized intellectual property research and verification firm. Lexington IP Services completed its verification and confirmed the accuracy and validity of all registrations as of January 22, 2026. Aurelius's chain of title to all 217 works has been fully verified and is complete and unbroken, running from the original creators and producers through a documented succession of assignments and work-for-hire agreements to Aurelius and/or AMA as the current and exclusive copyright owners.

V. Legal Basis — Copyright Infringement

Brindoval's unauthorized reproduction, distribution, and/or public performance of the 217 Aurelius titles through its FAST channels constitutes infringement of Aurelius's exclusive rights under Sections 106 and 501 of the Copyright Act, 17 U.S.C. §§ 106 and 501. Each unauthorized reproduction, each unauthorized distribution, and each unauthorized public performance of each of the 217 works constitutes a separate and independent act of copyright infringement, giving rise to separate liability and separate entitlement to damages.

Several additional legal points bear emphasis:

(a) StreamNow's Purported Sublicense Provides No Defense. As set forth in detail in Section III above, StreamNow itself had no valid license from Aurelius and therefore had no rights to sublicense. A sublicensee cannot acquire greater rights than those possessed by its sublicensor. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002); Effects Associates, Inc. v. Cohen, 908 F.2d 555, 559 (9th Cir. 1990). The purported sublicense from StreamNow to Brindoval is void ab initio and cannot serve as a defense to Aurelius's infringement claims.

(b) Contributory and Vicarious Liability. Brindoval may also face liability for contributory or vicarious copyright infringement to the extent that it had knowledge or reason to know that the content it was distributing was unlicensed, or to the extent that Brindoval derived a direct financial benefit from the infringing activity while possessing the right and ability to supervise and control the infringing conduct. See Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005); Fonovisa, Inc. v. Cherry Auction, Inc., 76 F.3d 259, 262 (9th Cir. 1996). The extent of Brindoval's knowledge, its due diligence (or lack thereof) regarding the chain of rights, and its financial arrangements with StreamNow are matters that Aurelius intends to investigate further.

(c) Supplemental State Law Claims. In addition to federal copyright infringement, Aurelius reserves all rights to pursue supplemental state law claims, including but not limited to claims for unfair business practices under California Business and Professions Code §§ 17200 et seq., unjust enrichment, conversion, and any other claims arising from Brindoval's unauthorized exploitation of Aurelius's content.

Aurelius expressly reserves all rights to pursue claims against Brindoval for both direct and secondary copyright infringement, as well as all supplemental state and common law claims that may be available.

We note further that the total revenue attributable to the unauthorized exploitation of Aurelius content across StreamNow's platform and sublicensed channels — including Brindoval's channels — has been estimated at approximately $38.6 million over the twenty-two-month infringement period. This estimate, which is based on a forensic financial analysis conducted by CipherTrace Analytics, LLC, a nationally recognized forensic accounting and analytics firm, includes the following revenue components:

• Subscription-related revenue: approximately $22.4 million

• Advertising revenue: approximately $9.7 million

• Sublicensing fees: approximately $6.5 million

These figures represent the aggregate revenues across all parties involved in the unauthorized distribution chain and are subject to further refinement as Aurelius's investigation continues. The revenues attributable specifically to Brindoval's exploitation of Aurelius content will be determined through the accounting demanded below and through discovery in the event that litigation becomes necessary.

VI. Demands

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

A. Immediate Takedown

Brindoval must immediately cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned content on any and all FAST channels, platforms, services, and distribution outlets operated, controlled, managed, or supplied by Brindoval, whether directly or through any affiliate, subsidiary, partner, vendor, or agent.

For purposes of this demand, "immediately" means within the time reasonably required to effect removal, but in no event later than the date and time of Brindoval's receipt of this letter. Aurelius expects that Brindoval will prioritize removal of the infringing content and will not delay removal pending internal review, legal analysis, or consultation with StreamNow or any other party.

All 217 Aurelius titles — comprising 142 feature films and 75 television series (1,038 total episodes) — must be removed in their entirety from all Brindoval channels, platforms, and services, including but not limited to any content delivery networks, caching servers, transcoding servers, metadata repositories, EPG listings, promotional materials, and any other systems or channels through which the content is stored, accessed, or made available. A complete list of all 217 titles is available upon request and will be provided as an attachment to this letter or under separate cover.

B. Confirmation of Compliance

Brindoval must provide written confirmation that all Aurelius content has been fully and permanently removed from all Brindoval channels, platforms, and services within ten (10) business days of Brindoval's receipt of this letter. Such written confirmation should:

(i) identify by title each of the 217 works that has been removed;

(ii) confirm the date and time at which removal was completed;

(iii) confirm that no copies, reproductions, or cached versions of the Aurelius content remain on any system, server, or platform operated, controlled, or accessible by Brindoval; and

(iv) identify the individual at Brindoval responsible for verifying that the removal has been completed.

Written confirmation should be directed to the undersigned at the following address:

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

Email: wschultz@calderwoodharkness.com

C. Preservation of Records

Brindoval must immediately implement a litigation hold and preserve and retain all documents, communications, and electronically stored information ("ESI") relating to the matters described in this letter. Without limitation, the preservation obligation extends to the following categories of materials:

(i) The sublicense agreement or any other agreement, amendment, addendum, side letter, term sheet, or other document evidencing or relating to the arrangement between Brindoval and StreamNow Holdings, Inc. covering the Aurelius content, including all schedules, exhibits, content lists, and delivery specifications;

(ii) All communications — whether by email, instant message, text message, Meridian Solutions, Northgate Data Systems, or any other medium — between or among Brindoval and StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie, or any other party, concerning, referencing, or relating to Aurelius content, the Aurelius catalog, or the rights thereto;

(iii) All revenue, viewership, traffic, audience measurement, monetization, and financial data relating to the distribution, streaming, or any other exploitation of Aurelius content through Brindoval's channels, platforms, or services, including but not limited to advertising revenue reports, CPM data, impression counts, programmatic advertising records, subscription allocation reports, and sublicensing fee records;

(iv) Any due diligence, chain-of-rights verification, rights clearance, or legal review conducted by Brindoval (or on Brindoval's behalf) regarding the provenance, ownership, or licensing status of the Aurelius content prior to, at the time of, or subsequent to Brindoval's acquisition of the content from StreamNow or any other source; and

(v) Any internal memoranda, presentations, board materials, or other documents discussing or analyzing the Aurelius content, its commercial performance on Brindoval's channels, or the legal status of the rights thereto.

This preservation obligation extends to all custodians, systems, repositories, backup tapes, cloud storage, and archives within Brindoval's possession, custody, or control, including but not limited to the files and accounts of all individuals involved in content acquisition, content operations, business development, legal, finance, and executive management functions. Brindoval should promptly issue written litigation hold notices to all relevant custodians and IT personnel and should take affirmative steps to suspend any automatic deletion, overwriting, or recycling routines that might affect responsive materials.

Failure to preserve such records may result in spoliation sanctions, including adverse inference instructions, monetary sanctions, and other remedies, in any subsequent legal proceedings. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212 (S.D.N.Y. 2003); Fed. R. Civ. P. 37(e).

D. Accounting. Brindoval must provide a full and complete accounting of all revenues derived from the distribution, streaming, public performance, or any other exploitation of Aurelius content through Brindoval's channels, platforms, or services for the period from approximately April 1, 2024 through the date on which full takedown is completed. The accounting must include, at a minimum, the following categories of revenue:

(i) Advertising revenue, including revenue from programmatic advertising, direct-sold advertising, sponsorships, and any other advertising-related income;

(ii) Subscription revenue allocations, to the extent that any portion of subscription or access fees paid by end users is attributable to the availability of Aurelius content;

(iii) Sublicensing fees paid to or received from StreamNow or any other party in connection with the Aurelius content; and

(iv) Any other revenue streams, payments, credits, offsets, or financial benefits of any kind derived from or attributable to the exploitation of Aurelius content.

The accounting should be provided within thirty (30) calendar days of receipt of this letter and should be supported by underlying financial records and documentation sufficient to permit independent verification.

VII. Reservation of Rights

Aurelius expressly reserves all rights and remedies available to it under federal and state law, in equity, and at common law, including but not limited to the following:

(a) Claims for copyright infringement under 17 U.S.C. §§ 106 and 501;

(b) Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), which, for the 189 timely-registered works alone, could result in statutory damage exposure of up to $28,350,000;

(c) Actual damages sustained by Aurelius and the infringer's profits attributable to the infringement under 17 U.S.C. § 504(b);

(d) Preliminary and permanent injunctive relief under 17 U.S.C. § 502, including orders requiring the impoundment and destruction of all infringing copies;

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

(f) State law claims, including but not limited to claims for unfair business practices under California Business and Professions Code §§ 17200 et seq., unjust enrichment, conversion, and any other applicable claims.

Nothing in this letter shall be construed as a waiver, release, or limitation of any of Aurelius's rights, claims, or remedies, whether arising under federal law, state law, equity, or contract. This letter is not intended to be, and shall not be deemed to be, a comprehensive or exhaustive statement of all of Aurelius's claims, rights, or remedies. Aurelius expressly reserves the right to assert additional claims, identify additional infringing works, and seek additional remedies as its investigation continues.

Aurelius's willingness to provide a ten-business-day window for Brindoval to confirm compliance is extended as a professional courtesy and is without prejudice to Aurelius's right to pursue immediate legal action, including emergency injunctive relief through the filing of a motion for a temporary restraining order, if circumstances warrant. Aurelius is prepared to file suit in the United States District Court for the Central District of California should Brindoval fail to comply with the demands set forth herein or should Aurelius otherwise determine that judicial intervention is necessary to protect its rights.

VIII. Cooperation Invitation

We wish to note that if Brindoval promptly and fully complies with each of the demands set forth in this letter, cooperates with Aurelius's ongoing investigation into the unauthorized distribution chain, and provides the requested accounting and document preservation in a timely and complete manner, Aurelius will take such cooperation into account in determining whether and to what extent to pursue legal claims against Brindoval. Aurelius recognizes that Brindoval may itself be a victim of StreamNow's and MDD's fraudulent representations regarding the availability of valid distribution rights, and Aurelius is prepared to consider that possibility in the context of Brindoval's response to this letter.

Aurelius encourages Brindoval to have its legal counsel contact the undersigned at the earliest opportunity to discuss compliance with the demands herein, including any questions regarding the scope of the takedown and preservation obligations, the format and content of the requested accounting, and the logistics of document preservation. Prompt engagement will be viewed favorably and will facilitate a constructive resolution of this matter.

IX. Closing

We request that all communications regarding this matter be directed exclusively to the undersigned at the contact information provided below. Please reference Matter No. 1017-00003 in all correspondence.

Wendy Schultz, Senior Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200

Email: wschultz@calderwoodharkness.com

We trust that Brindoval will treat this matter with the urgency it demands and will take immediate steps to cease the unauthorized exploitation of Aurelius's copyrighted works.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Wendy Schultz Senior Associate 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200

Email: wschultz@calderwoodharkness.com

cc: Marcus Delgado, Partner, Calderwood & Harkness LLP cc: Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC cc: Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Global Media Group PLC

Enclosure: Representative list of Aurelius-owned titles at issue (to be provided under separate cover)

CALDERWOOD & HARKNESS LLP Attorneys at Law 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200 Facsimile: (310) 555-7201 www.calderwoodharkness.com
March 14, 2026
VIA FEDEX OVERNIGHT DELIVERY AND EMAIL
CONFIDENTIAL — URGENT
Brindoval Channel Networks, Inc. 2700 Commerce Street, Suite 1400 Dallas, Texas 75201
Attention: General Counsel / Legal Department
Re: Unauthorized Distribution of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Takedown and Preservation of Records
Our Matter No. 1017-00003
To the General Counsel:
I. Introduction and Identification of Client
This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated in England and Wales (Companies House Registration No. 08724561), with its principal executive offices located 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.
Aurelius is a leading global media and entertainment conglomerate with fiscal year 2025 revenues of approximately £1.87 billion (approximately $2.36 billion at current exchange rates). Aurelius is listed on the London Stock Exchange (AIM: AGLM) and is one of the largest independent content libraries in the world. Aurelius owns and controls a comprehensive content library of over 4,200 film and television titles, spanning multiple genres and decades of production. Among its internationally recognized properties are the "Meridian" franchise (comprising six theatrical feature films with a combined global box office of $1.43 billion), the "Iron Compass" series (four seasons, forty-eight episodes, averaging 9.2 million viewers per episode in the United Kingdom), and the "Thornfield" period drama catalog (twelve titles, recipient of seven BAFTA awards). These properties, along with the remainder of Aurelius's extensive content library, represent substantial creative, financial, and strategic investments that Aurelius vigilantly protects.
We write to you on behalf of Aurelius and AMA concerning the unauthorized distribution of copyrighted audiovisual works owned by Aurelius through streaming channels operated or controlled by Brindoval Channel Networks, Inc. ("Brindoval"). The facts described in this letter constitute serious violations of Aurelius's exclusive rights under the United States Copyright Act, 17 U.S.C. §§ 101 et seq., and we demand immediate corrective action as set forth below.
II. Nature of the Infringement and Brindoval's Involvement
Through ongoing monitoring, forensic investigation, and industry intelligence, Aurelius has determined that Brindoval is currently distributing, reproducing, and/or publicly performing copyrighted audiovisual works owned exclusively by Aurelius through one or more FAST (Free Ad-Supported Streaming Television) channels that Brindoval operates, controls, or otherwise makes available to the public. The infringing activity encompasses the unauthorized streaming, caching, reproduction, and public performance of Aurelius-owned content to end users across the United States and potentially in other territories.
The content at issue comprises at least 217 titles, consisting of 142 feature films and 75 television series comprising a total of 1,038 episodes, all of which are owned exclusively by Aurelius and/or Aurelius Media Americas, Inc. Valid United States Copyright Office registrations exist for each of these works, as detailed further in Section IV below. The affected titles include, but are not limited to, the following key franchises and properties from the Aurelius catalog:
• All six films in the "Meridian" franchise;
• All four seasons (forty-eight episodes) of the "Iron Compass" series;
• All twelve titles in the "Thornfield" period drama catalog; and
• Numerous additional feature films and television series from the broader Aurelius content library.
A representative list of the 217 affected titles is available upon request and will be provided as an attachment to this letter or under separate cover. We urge Brindoval to contact the undersigned promptly if it requires the complete title list to facilitate expeditious removal of all infringing content.
Based on the evidence gathered through Aurelius's investigation, including timestamped captures, metadata analysis, and platform monitoring, the unauthorized exploitation of Aurelius content on Brindoval's channels has been ongoing since approximately April 1, 2024, spanning a period of at least twenty-two (22) months through the date of this letter. The scope and duration of this unauthorized distribution are deeply concerning to our client and represent a substantial and continuing injury to Aurelius's exclusive rights and commercial interests.
III. Source of the Unauthorized Content — The StreamNow Sublicense
Upon thorough investigation, Aurelius has established that Brindoval obtained the Aurelius content through a sublicense from StreamNow Holdings, Inc. ("StreamNow"), a corporation organized under the laws of the State of Delaware (Secretary of State File No. 7291843), with its principal offices at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a streaming "super-aggregator" platform that bundles content from multiple sources and sublicenses assembled content bundles to third-party FAST channel operators, including Brindoval.
StreamNow purported to acquire rights to distribute Aurelius content through a "Content Distribution Agreement" allegedly executed on or about March 15, 2024, with an entity known as Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430), with a principal address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.
Aurelius's investigation has revealed the following critical facts regarding MDD and the provenance of the purported rights:
(a) MDD's sole member and manager is Franklin Ogilvie, a former mid-level licensing manager at Aurelius Media Americas, Inc. Mr. Ogilvie's employment with AMA terminated on June 30, 2021, following an internal investigation that uncovered unauthorized access by Mr. Ogilvie to Aurelius's proprietary content management systems, including digital asset management platforms and rights databases.
(b) In connection with the termination of his employment, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, an explicit and unconditional prohibition on the use of any Aurelius intellectual property, including but not limited to copyrighted audiovisual works, trademarks, trade secrets, and proprietary business information. The separation agreement also contained non-compete and non-solicitation covenants restricting Mr. Ogilvie's activities in the media licensing and distribution sector.
(c) Notwithstanding these restrictions, Mr. Ogilvie subsequently formed MDD and, operating through that entity, purported to grant StreamNow distribution rights to the Aurelius content catalog — rights that Mr. Ogilvie and MDD never possessed and had no authority to grant.
We wish to make the following points absolutely clear:
Aurelius has never granted MDD, Franklin Ogilvie, StreamNow Holdings, Inc., or any other intermediary any license, sublicense, or distribution authority of any kind over any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius or any Aurelius affiliate. No individual or entity within the Aurelius corporate family has ever authorized, ratified, or acquiesced in any purported grant of rights by MDD or Mr. Ogilvie to any third party.
Consequently, StreamNow had no valid rights to sublicense Aurelius content to Brindoval or to any other party. The purported sublicense from StreamNow to Brindoval is derived from a chain of title that is fatally defective at its inception, as MDD and Mr. Ogilvie possessed no rights whatsoever to convey. It is a well-established principle of copyright law that a sublicensee's rights cannot exceed those of its sublicensor. Because StreamNow held no valid license from Aurelius, any sublicense purportedly granted by StreamNow to Brindoval is void and without legal effect and provides no defense to Brindoval's infringement of Aurelius's copyrights.
IV. Aurelius's Rights — Copyright Ownership and Registration
Aurelius and/or AMA are the exclusive owners of all copyrights in the 217 audiovisual works at issue, including all exclusive rights of reproduction, distribution, public performance, and display under Section 106 of the Copyright Act, 17 U.S.C. § 106. Aurelius's copyright ownership encompasses all formats, media, and distribution platforms, including without limitation theatrical, home video, television, cable, satellite, streaming, FAST, AVOD, SVOD, TVOD, and all other current and future forms of exploitation.
Of the 217 titles at issue, 189 titles have valid, timely United States Copyright Office registrations that were filed either within three months of first publication or prior to the commencement of the infringement. These timely registrations render all 189 titles eligible for the full range of remedies available under the Copyright Act, including:
• Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2); and
• Recovery of attorneys' fees and full costs under 17 U.S.C. § 505.
An additional 28 titles have valid United States Copyright Office registrations that, while confirming Aurelius's copyright ownership, post-date the commencement of the infringing activity. These 28 titles are eligible for recovery of actual damages sustained by Aurelius as well as the infringer's profits attributable to the infringement under 17 U.S.C. § 504(b).
The copyright registration status of all 217 titles has been independently verified by Lexington IP Services, Inc., a nationally recognized intellectual property research and verification firm. Lexington IP Services completed its verification and confirmed the accuracy and validity of all registrations as of January 22, 2026. Aurelius's chain of title to all 217 works has been fully verified and is complete and unbroken, running from the original creators and producers through a documented succession of assignments and work-for-hire agreements to Aurelius and/or AMA as the current and exclusive copyright owners.
V. Legal Basis — Copyright Infringement
Brindoval's unauthorized reproduction, distribution, and/or public performance of the 217 Aurelius titles through its FAST channels constitutes infringement of Aurelius's exclusive rights under Sections 106 and 501 of the Copyright Act, 17 U.S.C. §§ 106 and 501. Each unauthorized reproduction, each unauthorized distribution, and each unauthorized public performance of each of the 217 works constitutes a separate and independent act of copyright infringement, giving rise to separate liability and separate entitlement to damages.
Several additional legal points bear emphasis:
(a) StreamNow's Purported Sublicense Provides No Defense. As set forth in detail in Section III above, StreamNow itself had no valid license from Aurelius and therefore had no rights to sublicense. A sublicensee cannot acquire greater rights than those possessed by its sublicensor. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002); Effects Associates, Inc. v. Cohen, 908 F.2d 555, 559 (9th Cir. 1990). The purported sublicense from StreamNow to Brindoval is void ab initio and cannot serve as a defense to Aurelius's infringement claims.
(b) Contributory and Vicarious Liability. Brindoval may also face liability for contributory or vicarious copyright infringement to the extent that it had knowledge or reason to know that the content it was distributing was unlicensed, or to the extent that Brindoval derived a direct financial benefit from the infringing activity while possessing the right and ability to supervise and control the infringing conduct. See Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005); Fonovisa, Inc. v. Cherry Auction, Inc., 76 F.3d 259, 262 (9th Cir. 1996). The extent of Brindoval's knowledge, its due diligence (or lack thereof) regarding the chain of rights, and its financial arrangements with StreamNow are matters that Aurelius intends to investigate further.
(c) Supplemental State Law Claims. In addition to federal copyright infringement, Aurelius reserves all rights to pursue supplemental state law claims, including but not limited to claims for unfair business practices under California Business and Professions Code §§ 17200 et seq., unjust enrichment, conversion, and any other claims arising from Brindoval's unauthorized exploitation of Aurelius's content.
Aurelius expressly reserves all rights to pursue claims against Brindoval for both direct and secondary copyright infringement, as well as all supplemental state and common law claims that may be available.
We note further that the total revenue attributable to the unauthorized exploitation of Aurelius content across StreamNow's platform and sublicensed channels — including Brindoval's channels — has been estimated at approximately $38.6 million over the twenty-two-month infringement period. This estimate, which is based on a forensic financial analysis conducted by CipherTrace Analytics, LLC, a nationally recognized forensic accounting and analytics firm, includes the following revenue components:
• Subscription-related revenue: approximately $22.4 million
• Advertising revenue: approximately $9.7 million
• Sublicensing fees: approximately $6.5 million
These figures represent the aggregate revenues across all parties involved in the unauthorized distribution chain and are subject to further refinement as Aurelius's investigation continues. The revenues attributable specifically to Brindoval's exploitation of Aurelius content will be determined through the accounting demanded below and through discovery in the event that litigation becomes necessary.
VI. Demands
In light of the foregoing, Aurelius hereby makes the following demands of Brindoval:
A. Immediate Takedown
Brindoval must immediately cease all reproduction, distribution, public performance, and any other exploitation of all Aurelius-owned content on any and all FAST channels, platforms, services, and distribution outlets operated, controlled, managed, or supplied by Brindoval, whether directly or through any affiliate, subsidiary, partner, vendor, or agent.
For purposes of this demand, "immediately" means within the time reasonably required to effect removal, but in no event later than the date and time of Brindoval's receipt of this letter. Aurelius expects that Brindoval will prioritize removal of the infringing content and will not delay removal pending internal review, legal analysis, or consultation with StreamNow or any other party.
All 217 Aurelius titles — comprising 142 feature films and 75 television series (1,038 total episodes) — must be removed in their entirety from all Brindoval channels, platforms, and services, including but not limited to any content delivery networks, caching servers, transcoding servers, metadata repositories, EPG listings, promotional materials, and any other systems or channels through which the content is stored, accessed, or made available. A complete list of all 217 titles is available upon request and will be provided as an attachment to this letter or under separate cover.
B. Confirmation of Compliance
Brindoval must provide written confirmation that all Aurelius content has been fully and permanently removed from all Brindoval channels, platforms, and services within ten (10) business days of Brindoval's receipt of this letter. Such written confirmation should:
(i) identify by title each of the 217 works that has been removed;
(ii) confirm the date and time at which removal was completed;
(iii) confirm that no copies, reproductions, or cached versions of the Aurelius content remain on any system, server, or platform operated, controlled, or accessible by Brindoval; and
(iv) identify the individual at Brindoval responsible for verifying that the removal has been completed.
Written confirmation should be directed to the undersigned at the following address:
Wendy Schultz, Senior Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Email: wschultz@calderwoodharkness.com
C. Preservation of Records
Brindoval must immediately implement a litigation hold and preserve and retain all documents, communications, and electronically stored information ("ESI") relating to the matters described in this letter. Without limitation, the preservation obligation extends to the following categories of materials:
(i) The sublicense agreement or any other agreement, amendment, addendum, side letter, term sheet, or other document evidencing or relating to the arrangement between Brindoval and StreamNow Holdings, Inc. covering the Aurelius content, including all schedules, exhibits, content lists, and delivery specifications;
(ii) All communications — whether by email, instant message, text message, Meridian Solutions, Northgate Data Systems, or any other medium — between or among Brindoval and StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie, or any other party, concerning, referencing, or relating to Aurelius content, the Aurelius catalog, or the rights thereto;
(iii) All revenue, viewership, traffic, audience measurement, monetization, and financial data relating to the distribution, streaming, or any other exploitation of Aurelius content through Brindoval's channels, platforms, or services, including but not limited to advertising revenue reports, CPM data, impression counts, programmatic advertising records, subscription allocation reports, and sublicensing fee records;
(iv) Any due diligence, chain-of-rights verification, rights clearance, or legal review conducted by Brindoval (or on Brindoval's behalf) regarding the provenance, ownership, or licensing status of the Aurelius content prior to, at the time of, or subsequent to Brindoval's acquisition of the content from StreamNow or any other source; and
(v) Any internal memoranda, presentations, board materials, or other documents discussing or analyzing the Aurelius content, its commercial performance on Brindoval's channels, or the legal status of the rights thereto.
This preservation obligation extends to all custodians, systems, repositories, backup tapes, cloud storage, and archives within Brindoval's possession, custody, or control, including but not limited to the files and accounts of all individuals involved in content acquisition, content operations, business development, legal, finance, and executive management functions. Brindoval should promptly issue written litigation hold notices to all relevant custodians and IT personnel and should take affirmative steps to suspend any automatic deletion, overwriting, or recycling routines that might affect responsive materials.
Failure to preserve such records may result in spoliation sanctions, including adverse inference instructions, monetary sanctions, and other remedies, in any subsequent legal proceedings. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212 (S.D.N.Y. 2003); Fed. R. Civ. P. 37(e).
D. Accounting. Brindoval must provide a full and complete accounting of all revenues derived from the distribution, streaming, public performance, or any other exploitation of Aurelius content through Brindoval's channels, platforms, or services for the period from approximately April 1, 2024 through the date on which full takedown is completed. The accounting must include, at a minimum, the following categories of revenue:
(i) Advertising revenue, including revenue from programmatic advertising, direct-sold advertising, sponsorships, and any other advertising-related income;
(ii) Subscription revenue allocations, to the extent that any portion of subscription or access fees paid by end users is attributable to the availability of Aurelius content;
(iii) Sublicensing fees paid to or received from StreamNow or any other party in connection with the Aurelius content; and
(iv) Any other revenue streams, payments, credits, offsets, or financial benefits of any kind derived from or attributable to the exploitation of Aurelius content.
The accounting should be provided within thirty (30) calendar days of receipt of this letter and should be supported by underlying financial records and documentation sufficient to permit independent verification.
VII. Reservation of Rights
Aurelius expressly reserves all rights and remedies available to it under federal and state law, in equity, and at common law, including but not limited to the following:
(a) Claims for copyright infringement under 17 U.S.C. §§ 106 and 501;
(b) Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), which, for the 189 timely-registered works alone, could result in statutory damage exposure of up to $28,350,000;
(c) Actual damages sustained by Aurelius and the infringer's profits attributable to the infringement under 17 U.S.C. § 504(b);
(d) Preliminary and permanent injunctive relief under 17 U.S.C. § 502, including orders requiring the impoundment and destruction of all infringing copies;
(e) Recovery of full attorneys' fees and costs under 17 U.S.C. § 505; and
(f) State law claims, including but not limited to claims for unfair business practices under California Business and Professions Code §§ 17200 et seq., unjust enrichment, conversion, and any other applicable claims.
Nothing in this letter shall be construed as a waiver, release, or limitation of any of Aurelius's rights, claims, or remedies, whether arising under federal law, state law, equity, or contract. This letter is not intended to be, and shall not be deemed to be, a comprehensive or exhaustive statement of all of Aurelius's claims, rights, or remedies. Aurelius expressly reserves the right to assert additional claims, identify additional infringing works, and seek additional remedies as its investigation continues.
Aurelius's willingness to provide a ten-business-day window for Brindoval to confirm compliance is extended as a professional courtesy and is without prejudice to Aurelius's right to pursue immediate legal action, including emergency injunctive relief through the filing of a motion for a temporary restraining order, if circumstances warrant. Aurelius is prepared to file suit in the United States District Court for the Central District of California should Brindoval fail to comply with the demands set forth herein or should Aurelius otherwise determine that judicial intervention is necessary to protect its rights.
VIII. Cooperation Invitation
We wish to note that if Brindoval promptly and fully complies with each of the demands set forth in this letter, cooperates with Aurelius's ongoing investigation into the unauthorized distribution chain, and provides the requested accounting and document preservation in a timely and complete manner, Aurelius will take such cooperation into account in determining whether and to what extent to pursue legal claims against Brindoval. Aurelius recognizes that Brindoval may itself be a victim of StreamNow's and MDD's fraudulent representations regarding the availability of valid distribution rights, and Aurelius is prepared to consider that possibility in the context of Brindoval's response to this letter.
Aurelius encourages Brindoval to have its legal counsel contact the undersigned at the earliest opportunity to discuss compliance with the demands herein, including any questions regarding the scope of the takedown and preservation obligations, the format and content of the requested accounting, and the logistics of document preservation. Prompt engagement will be viewed favorably and will facilitate a constructive resolution of this matter.
IX. Closing
We request that all communications regarding this matter be directed exclusively to the undersigned at the contact information provided below. Please reference Matter No. 1017-00003 in all correspondence.
Wendy Schultz, Senior Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200
Email: wschultz@calderwoodharkness.com
We trust that Brindoval will treat this matter with the urgency it demands and will take immediate steps to cease the unauthorized exploitation of Aurelius's copyrighted works.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Wendy Schultz Senior Associate 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200
Email: wschultz@calderwoodharkness.com
cc: Marcus Delgado, Partner, Calderwood & Harkness LLP cc: Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC cc: Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Global Media Group PLC
Enclosure: Representative list of Aurelius-owned titles at issue (to be provided under separate cover)

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