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) 553-4800 Facsimile: (310) 553-4801

Writer's Direct Dial: (310) 553-4837 Writer's Facsimile: (310) 553-4899 Writer's Email: wschultz@calderwoodharkness.com

VIA INTERNATIONAL COURIER (Granite Harbor Enterprises — TRACKED/SIGNED) AND EMAIL

March 14, 2026

Pacific Lantern Digital Pty Ltd Level 18, One International Towers 100 Barangaroo Avenue Sydney, NSW 2000 Australia

Attn: General Counsel / Chief Executive Officer

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

Matter No. 1017-00003

Dear Sir or Madam:

I. Introduction and Identification of Counsel

This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated under the laws of England and Wales (Companies House Registration No. 08724561), with its principal office and headquarters located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius operates in the United States through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc., which maintains offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. Aurelius Media Americas, Inc. serves as the U.S.-based operational arm for Aurelius's distribution, licensing, and rights enforcement activities throughout the Americas region.

Aurelius is a global media and entertainment conglomerate listed on the Alternative Investment Market of the London Stock Exchange (AIM: AGLM). For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately US$2.36 billion at prevailing exchange rates), making it one of the largest independent media companies in the world. Aurelius's business activities span theatrical film production and distribution, scripted and unscripted television programming, digital content licensing, home entertainment, and global merchandising.

Aurelius owns a content library comprising more than 4,200 film and television titles, including internationally recognized and commercially significant properties. Among these are:

• The "Meridian" franchise, which comprises six feature films released between 2012 and 2024 and has earned a combined global box office of approximately US$1.43 billion, with extensive downstream licensing revenues in home entertainment, pay television, subscription video-on-demand, and merchandising;

• The "Iron Compass" series, a critically acclaimed and commercially successful dramatic television series spanning four seasons and forty-eight episodes, which averaged approximately 9.2 million viewers per episode in the United Kingdom during its initial broadcast run and has been licensed to broadcasters and streaming platforms in over seventy territories worldwide; and

• The "Thornfield" period drama catalog, a collection of twelve individually titled feature films and limited series that have collectively received seven British Academy of Film and Television Arts (BAFTA) awards and numerous other accolades, and which continue to generate significant licensing and syndication revenues globally.

We write to you in connection with the unauthorized exploitation by Pacific Lantern Digital Pty Ltd ("Pacific Lantern" or "your company") of copyrighted audiovisual works owned by Aurelius. The facts set forth below demonstrate that Pacific Lantern has been distributing a substantial volume of Aurelius-owned content without any license, consent, or authorization from Aurelius or any entity lawfully authorized to grant such rights. This letter constitutes a formal demand for immediate cessation and takedown of all infringing content, preservation of relevant records, and compliance with the additional requirements detailed herein.

II. Background — The Unauthorized Sublicensing Chain

Our investigation has uncovered a multi-layered unauthorized sublicensing scheme through which Aurelius's copyrighted content has been misappropriated and distributed without authorization. The relevant parties and the chain of unauthorized distribution are set forth below.

A. StreamNow Holdings, Inc. and the Infringing Platform

StreamNow Holdings, Inc. ("StreamNow") is a Delaware corporation (State of Delaware Division of Corporations File No. 7291843) with its principal offices located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a streaming "super-aggregator" platform—a digital distribution service that bundles and makes available content from multiple studios, independent distributors, and other content suppliers. StreamNow's platform is currently available to consumers in fourteen countries across North America, Europe, and the Asia-Pacific region.

StreamNow is a privately held company. Its majority equity ownership—approximately sixty-two percent (62%) on a fully diluted basis—is held by Pinnacle Ventures Fund III, LP, a venture capital fund. StreamNow's estimated consolidated revenue for the fiscal year ending December 31, 2025 was approximately US$312 million, derived from a combination of subscription fees, advertising revenue from its ad-supported tier, and sublicensing fees collected from downstream distribution partners.

Without any authorization from Aurelius—whether directly, through Aurelius Media Americas, Inc., or through any authorized agent—StreamNow ingested at least two hundred seventeen (217) Aurelius-owned audiovisual works into its platform and made those works available to its subscribers and through sublicensed distribution channels. The 217 unauthorized works comprise one hundred forty-two (142) feature films and seventy-five (75) television series encompassing a total of one thousand thirty-eight (1,038) individual episodes. The unauthorized exploitation of these works commenced on or about April 1, 2024, has continued for an approximate period of twenty-two (22) months through at least January 31, 2026, and is believed to be ongoing as of the date of this letter.

B. Meridian Digital Distributors, LLC — The Unauthorized Intermediary

StreamNow purportedly obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with a registered address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD represented itself as an authorized distributor of the Aurelius titles in question.

Our investigation has established that MDD's sole member and manager is Franklin Ogilvie. Mr. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc., where he was employed from approximately September 2017 through June 30, 2021. Mr. Ogilvie's employment with Aurelius Media Americas, Inc. was terminated effective June 30, 2021, following an internal investigation that substantiated concerns regarding Mr. Ogilvie's unauthorized access to and use of Aurelius's proprietary content management systems and licensing databases. In connection with his departure, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, a comprehensive non-competition covenant, a non-solicitation clause, and an explicit prohibition on the use, exploitation, reproduction, or distribution of any Aurelius intellectual property, including without limitation all audiovisual content, trademarks, trade secrets, and proprietary information.

Aurelius's records—including its centralized licensing database, board and management committee records, and authorized distributor registry—unequivocally confirm that Aurelius never granted MDD any license, sublicense, distribution authorization, agency appointment, or any other form of consent to exploit, distribute, or make available any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius for any purpose. Mr. Ogilvie had no authority, actual or apparent, to grant any rights in Aurelius content following (or indeed prior to) the termination of his employment.

Accordingly, any purported "Content Distribution Agreement" between MDD and StreamNow—which our investigation indicates was executed on or about March 15, 2024, and which purported to grant StreamNow rights to distribute the Aurelius titles identified therein—conveyed no rights whatsoever. MDD had no rights to grant, and StreamNow received nothing of value, as a matter of copyright law. The entire foundation of the purported sublicensing chain was fraudulent and void ab initio.

C. Pacific Lantern's Receipt of Unlawfully Sublicensed Content

StreamNow, in turn, sublicensed bundles of content—including the 217 Aurelius-owned works described above—to at least four third-party FAST (Free Ad-Supported Streaming Television) channel operators. Pacific Lantern Digital Pty Ltd is one of those four identified sublicensees. The other three identified FAST channel sublicensees are:

1. Brindoval Channel Networks, Inc., located in Dallas, Texas;

2. BrightLoop Media, LLC, located in Miami, Florida; and

3. Velvet Stream Partners, LP, located in Toronto, Ontario, Canada.

Pacific Lantern has been distributing Aurelius content through its FAST channels—making the works available to the public for streaming and viewing—without any authorization from, or license agreement with, Aurelius or any entity lawfully entitled to grant such authorization. Pacific Lantern has no direct, indirect, or derivative contractual relationship with Aurelius whatsoever, and Aurelius has never consented to Pacific Lantern's exploitation of its content.

The legal consequence of the facts set forth above is clear: because StreamNow itself had no valid rights to the Aurelius content—its only purported source of rights being MDD, which had no authority to grant any rights—StreamNow's sublicense to Pacific Lantern conveyed no valid rights to Pacific Lantern. It is a fundamental principle of both U.S. and international copyright law that a sublicensor cannot convey greater rights than it possesses (nemo dat quod non habet). Pacific Lantern's distribution of Aurelius content is therefore unauthorized, unlicensed, and constitutes actionable copyright infringement.

III. Aurelius's Copyrights in the Works at Issue

Aurelius, directly and through its wholly-owned subsidiary Aurelius Media Americas, Inc., is the exclusive owner of all United States and international copyrights in each of the 217 audiovisual works that Pacific Lantern has been distributing without authorization. The works at issue span a diverse range of Aurelius's content library and include, without limitation, titles from the "Meridian" franchise, the "Iron Compass" series, and the "Thornfield" period drama catalog, as well as numerous additional feature films, television series, and other audiovisual productions. A representative list of the 217 infringing titles is attached hereto as Exhibit A, which cross-references the Copyright Registration Summary Report prepared from the records of Lexington IP Services, Inc.

Of the 217 titles at issue:

• One hundred eighty-nine (189) works have valid, timely United States copyright registrations that were filed either within three months of the date of first publication of each respective work or prior to the commencement of infringement. These timely registrations qualify the works for the full range of remedies available under the United States Copyright Act, including statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), as well as recovery of full costs and reasonable attorneys' fees under 17 U.S.C. § 505.

• Twenty-eight (28) works have United States copyright registrations that were filed after the commencement of the infringing activity (i.e., registered between May 2024 and October 2025). While these registrations satisfy the jurisdictional prerequisite for filing suit under 17 U.S.C. § 411(a), they do not qualify for statutory damages or attorneys' fee awards under sections 412 and 504(c). Aurelius is, however, fully entitled to recover actual damages suffered and any profits of the infringer attributable to the infringement of these works under 17 U.S.C. § 504(b).

Verification of the registration status of all 217 works was completed on January 22, 2026, by Lexington IP Services, Inc., a nationally recognized intellectual property records and search firm, through a comprehensive search of the records of the United States Copyright Office. Lexington IP Services confirmed the validity of all registrations and the absence of any adverse claims, conflicting registrations, or title defects.

In addition, Aurelius's chain of title for all 217 works has been thoroughly reviewed and confirmed to be complete and without gaps. The chain of title documentation for each work, including original copyright assignment agreements, work-for-hire agreements, and certificates of registration, is maintained by Aurelius and is available for inspection as may be required in connection with any enforcement proceedings.

IV. Legal Basis — Copyright Infringement

Pacific Lantern's conduct constitutes copyright infringement under the United States Copyright Act, 17 U.S.C. §§ 101 et seq., and under applicable international copyright law. Specifically:

Pacific Lantern's unauthorized public performance, distribution, and reproduction of the 217 Aurelius-owned audiovisual works violates the exclusive rights of copyright owners under 17 U.S.C. § 106. Section 106 of the Copyright Act grants to the owner of a copyright the exclusive rights to do and to authorize any of the following: (1) to reproduce the copyrighted work in copies or phonorecords (§ 106(1)); (2) to prepare derivative works based upon the copyrighted work (§ 106(2)); (3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending (§ 106(3)); and (4) in the case of motion pictures and other audiovisual works, to perform the copyrighted work publicly (§ 106(4)). Pacific Lantern's activities—which include the ingestion, storage, streaming, and public display of Aurelius's copyrighted audiovisual works through its FAST channels—implicate each of these exclusive rights.

Such unauthorized acts constitute infringement under 17 U.S.C. § 501, 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."

Pacific Lantern cannot rely on StreamNow's purported sublicense as a defense to infringement. As set forth in detail above, StreamNow itself had no valid rights to sublicense the Aurelius content. The purported chain of rights traces back, in its entirety, to MDD, which had no authority whatsoever from Aurelius to license, distribute, or otherwise exploit any Aurelius-owned content. It is black-letter law that a sublicensor cannot convey greater rights than it possesses. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002) (a party cannot convey rights in a copyrighted work that it does not hold). Because MDD had no rights, StreamNow acquired no rights from MDD, and Pacific Lantern, in turn, acquired no rights from StreamNow. Pacific Lantern's purported sublicense is a legal nullity.

Moreover, StreamNow does not qualify for the safe harbor protections of Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512. StreamNow does not function as a passive hosting or conduit service within the meaning of § 512(a) through (d). Rather, StreamNow actively curates, ingests, licenses, and monetizes the content on its platform—exercising editorial control over the selection and arrangement of content offerings, entering into affirmative sublicense agreements with downstream distributors, and deriving direct financial benefit from the exploitation of the content. StreamNow's active involvement in the content licensing chain places it squarely outside the scope of the DMCA safe harbor provisions. StreamNow's inability to avail itself of safe harbor protection further underscores the invalidity of any downstream sublicense that StreamNow purported to grant, including its sublicense to Pacific Lantern.

Aurelius's investigation into the facts underlying this demand has been supported by extensive digital forensic analysis performed by CipherTrace Analytics, LLC, a leading digital forensics and e-discovery firm retained by Calderwood & Harkness for this purpose. The engagement was led by Dr. Nathan Frey, a digital forensics expert with over fifteen years of experience in online content identification and rights enforcement investigations. CipherTrace's forensic analysis confirmed the presence of all 217 Aurelius-owned titles on the StreamNow platform and on each of the downstream sublicensed channels, including Pacific Lantern's FAST channels. CipherTrace's analysis employed proprietary audio-visual fingerprinting technology, metadata extraction, and comparative analysis against Aurelius's master content registry to verify the identity and provenance of each infringing work.

V. Revenue and Damages Context

The scale of the unauthorized exploitation at issue is substantial, and Aurelius has suffered—and continues to suffer—significant economic harm as a result.

CipherTrace Analytics, LLC's forensic analysis attributes a total of approximately US$38.6 million in revenue to StreamNow's unauthorized exploitation of Aurelius content over the twenty-two-month infringement period (April 1, 2024 through January 31, 2026). This revenue is broken down as follows:

These figures represent the revenues directly attributable to the Aurelius titles based on viewership data, content engagement metrics, and sublicensing fee allocation analyses performed by CipherTrace.

In addition, Aurelius engaged Hargrove Economic Consulting Group, LLC, a nationally recognized economic consulting firm specializing in intellectual property damages quantification, to prepare a preliminary damages estimate. The engagement was led by Dr. Elena Vasquez, a Ph.D. economist with extensive experience in entertainment industry damages analyses. Dr. Vasquez's preliminary assessment estimates net recoverable damages of approximately US$41.3 million, based on a combination of:

• Actual damages in the form of lost licensing revenue of approximately US$14.2 million, representing the fair market value licensing fees that Aurelius would have received had the 217 works been licensed through authorized channels during the relevant period; and

• Infringer's profits attributable to the unauthorized exploitation of Aurelius content, with appropriate apportionment under 17 U.S.C. § 504(b) to exclude profits attributable to non-infringing content and to account for the infringer's deductible expenses.

As an alternative measure of damages, Aurelius may elect to recover statutory damages under 17 U.S.C. § 504(c)(2). For the 189 works with timely copyright registrations, Aurelius is entitled to seek statutory damages of up to $150,000 per work for willful infringement. If statutory damages are elected for all eligible works, Aurelius's potential statutory damages recovery would be up to US$28,350,000 for those 189 works alone. Combined with actual damages and profits for the remaining 28 works, Aurelius's total potential recovery under a statutory damages theory could reach or exceed US$32,550,000 (calculated as 217 works × $150,000, though statutory damages are available only for the 189 timely-registered works; the balance would be recovered as actual damages and profits).

Importantly, Pacific Lantern's own revenues derived from distributing Aurelius content through its FAST channels may be subject to disgorgement as part of the infringer's profits recoverable under 17 U.S.C. § 504(b). Pacific Lantern bears the burden of proving any deductible expenses and any elements of profit attributable to factors other than the copyrighted work. Aurelius intends to pursue full recovery of all profits earned by Pacific Lantern from the unauthorized exploitation of the 217 Aurelius titles.

Aurelius expressly reserves all rights to pursue damages and profits attributable to Pacific Lantern's unauthorized exploitation, whether in a standalone proceeding or as part of broader enforcement actions against StreamNow, MDD, and other parties in the unauthorized distribution chain.

VI. Demands

In light of the foregoing, Aurelius, through undersigned counsel, hereby makes the following demands upon Pacific Lantern Digital Pty Ltd:

A. Immediate Cessation and Takedown

Aurelius demands that Pacific Lantern immediately cease all reproduction, distribution, public performance, public display, digital transmission, and any other exploitation of each and every one of the 217 Aurelius-owned audiovisual works identified in Exhibit A hereto, including but not limited to all titles from the "Meridian" franchise, the "Iron Compass" series, and the "Thornfield" period drama catalog, and all other Aurelius titles that may have been made available through Pacific Lantern's channels or services.

Pacific Lantern must remove all Aurelius content from its FAST channels, servers, content delivery networks ("CDNs"), caching systems, backup systems, and any other distribution platforms, storage systems, or media within its custody or control. This removal must be comprehensive and must include the deletion or quarantine of all copies of Aurelius content, including any transcoded, reformatted, or derivative versions, from all systems and networks operated by or on behalf of Pacific Lantern.

B. Confirmation of Takedown

Aurelius demands that Pacific Lantern provide written confirmation, executed by an authorized officer or representative of Pacific Lantern, certifying that all Aurelius content has been fully and permanently removed from Pacific Lantern's channels, systems, servers, CDNs, and all other platforms and storage media within Pacific Lantern's custody or control. Such written confirmation must be delivered to the undersigned counsel within ten (10) business days of the date of this letter—that is, by no later than March 28, 2026.

The written confirmation should:

(a) identify by title and registration number each of the 217 works that have been removed;

(b) certify that no copies, in any format, of any of the identified works remain on any system, server, CDN, backup system, or other storage medium within Pacific Lantern's custody or control;

(c) identify any third-party service providers (including but not limited to CDN providers, cloud hosting providers, and technology partners) through which Pacific Lantern distributed or stored Aurelius content, and confirm that such providers have also been directed to remove all Aurelius content; and

(d) be signed under penalty of perjury or, at a minimum, under a certification that the statements made therein are true, complete, and accurate to the best of the signatory's knowledge and belief.

C. Preservation of Records

Aurelius hereby places Pacific Lantern on formal notice of its obligation to immediately preserve—and to refrain from destroying, deleting, altering, concealing, or otherwise disposing of—all documents, data, and records relating to the matters described in this letter. This preservation obligation includes, without limitation, the following categories of materials:

(a) All sublicense agreements, content distribution agreements, and any other contracts or arrangements between Pacific Lantern and StreamNow Holdings, Inc. (or any affiliate or agent thereof), including all amendments, addenda, schedules, exhibits, side letters, and related correspondence;

(b) All content received from or through StreamNow Holdings, Inc. (or any affiliate or agent thereof), including all delivery records, technical specifications, asset manifests, content identification metadata, watermark data, and digital rights management information;

(c) All revenues, viewership data, audience metrics, advertising revenue, subscription revenue, and any other financial records or reports relating to the distribution of any Aurelius-owned content through Pacific Lantern's channels, platforms, or services, whether generated internally or received from third parties;

(d) All internal and external communications—whether by email, instant message, text message, video conference, telephone, or any other medium—regarding the acquisition, licensing, distribution, monetization, or removal of any Aurelius-owned content, including but not limited to communications with or about StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie, or any other intermediary, broker, or third party; and

(e) All documents, data, and records relating to Pacific Lantern's due diligence or investigation (if any) into the provenance, ownership, or authorization of the content received from StreamNow, including any representations or warranties received from StreamNow regarding its rights to the content.

Pacific Lantern is advised that the failure to preserve documents and data in accordance with this notice may result in adverse inference instructions, evidentiary sanctions, and other penalties in any subsequent litigation. Aurelius will seek the full range of available sanctions against any party that fails to comply with its preservation obligations.

D. Accounting of Revenues

Aurelius requests that Pacific Lantern provide a full and complete accounting of all revenues—including but not limited to advertising revenue, subscription revenue, sublicensing fees, carriage fees, and any other income or consideration of any kind—derived from the distribution of the 217 Aurelius titles (and any other Aurelius-owned content) through Pacific Lantern's FAST channels, platforms, or other distribution services. This accounting should cover the entire period during which Pacific Lantern distributed any Aurelius content, and should be broken down by title, revenue category, and time period (monthly or quarterly, as available).

Aurelius requests that this accounting be provided within the same ten (10) business day period specified above (i.e., by no later than March 28, 2026), or, if additional time is reasonably required to compile the accounting, that Pacific Lantern communicate a specific and reasonable timeline for delivery of the accounting within the ten-business-day response period.

VII. Reservation of Rights

Aurelius expressly reserves all rights and remedies available to it at law and in equity, whether under United States federal or state law, Australian law, or the laws of any other applicable jurisdiction, including but not limited to:

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

(b) Claims for contributory copyright infringement and/or vicarious copyright infringement;

(c) Recovery of actual damages suffered by Aurelius as a result of the unauthorized exploitation of its copyrighted works, including lost licensing revenue and any other compensable harm;

(d) Recovery of infringer's profits attributable to the infringement, including profits earned by Pacific Lantern from the distribution of Aurelius content through its FAST channels;

(e) Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), with respect to all eligible works;

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

(g) Injunctive relief, including temporary restraining orders, preliminary injunctions, and permanent injunctions, to prevent any further unauthorized exploitation of Aurelius content;

(h) Any applicable claims under the Copyright Act 1968 (Cth) of Australia, or under any other foreign copyright laws, to the extent applicable to Pacific Lantern's activities; and

(i) Any and all other claims, remedies, and relief to which Aurelius may be entitled.

Nothing in this letter shall be construed as a waiver, release, or limitation of any of Aurelius's rights, claims, or remedies, whether or not expressly referenced herein. Aurelius's willingness to engage with Pacific Lantern at this pre-litigation stage, and its provision of an opportunity for Pacific Lantern to comply with the demands set forth above, should not be construed as an acceptance of any delay in enforcement, a limitation on the scope of Aurelius's claims, or an acknowledgment that Pacific Lantern's conduct is excusable or mitigated in any respect.

For your information, Aurelius has already served concurrent formal cease-and-desist and pre-suit demand letters on the following parties:

• StreamNow Holdings, Inc. (attention: Tobias Rennert, General Counsel);

• Meridian Digital Distributors, LLC and Franklin Ogilvie individually; and

• The three other identified FAST channel sublicensees: Brindoval Channel Networks, Inc., BrightLoop Media, LLC, and Velvet Stream Partners, LP.

Aurelius is pursuing coordinated enforcement action against all parties in the unauthorized distribution chain and will take whatever steps are necessary to protect its rights and recover all available damages and relief.

VIII. Consequences of Non-Compliance

Pacific Lantern is hereby placed on notice that if it fails to comply with the demands set forth in this letter within the specified timeframes, Aurelius will pursue all available legal remedies without further notice or delay. Such remedies include, but are not limited to:

• Filing suit against Pacific Lantern for copyright infringement in the United States District Court for the Central District of California, Los Angeles Division, and/or in any other court of competent jurisdiction, including courts in Australia or other jurisdictions where Pacific Lantern operates or distributes content;

• Seeking emergency injunctive relief, including temporary restraining orders and preliminary injunctions, to compel the immediate removal of all Aurelius content from Pacific Lantern's channels and systems;

• Seeking the maximum available statutory damages, actual damages, infringer's profits, attorneys' fees, and costs; and

• Pursuing any additional claims and remedies that may be available under applicable law.

Pacific Lantern is further advised that its continued distribution of Aurelius content after receipt of this notice will be treated as strong evidence of willful copyright infringement, exposing Pacific Lantern to enhanced statutory damages of up to $150,000 per work under 17 U.S.C. § 504(c)(2), as well as other enhanced penalties and remedies. Willfulness is a factual determination that courts consider in assessing damages, and continued exploitation of copyrighted works after receipt of a detailed takedown demand from the rights holder is a significant factor weighing in favor of a willfulness finding. See, e.g., Columbia Pictures Television, Inc. v. Krypton Broad. of Birmingham, Inc., 259 F.3d 1186, 1194 (9th Cir. 2001).

Aurelius has retained CipherTrace Analytics, LLC for ongoing forensic monitoring of Pacific Lantern's FAST channels and distribution platforms. Any continued distribution of Aurelius content after the date of this letter will be documented and preserved for use in any subsequent enforcement proceedings. Aurelius will also seek to recover any additional damages, profits, and costs arising from any post-notice infringement.

IX. Contact and Response Instructions

All responses, communications, and correspondence regarding this matter should be directed to:

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

Telephone: (310) 553-4837 Facsimile: (310) 553-4899

Email: wschultz@calderwoodharkness.com

Please reference Matter No. 1017-00003 in all correspondence relating to this matter.

We strongly encourage Pacific Lantern to engage experienced copyright counsel promptly and to respond to this letter within the timeframes set forth above. Aurelius is prepared to discuss an orderly resolution of this matter, but will not hesitate to initiate litigation if compliance is not forthcoming.

We trust that Pacific Lantern will treat this matter with the urgency it requires and will act promptly to comply with the demands set forth herein. Aurelius takes the protection of its intellectual property rights extremely seriously and will pursue all necessary measures to ensure that its copyrighted works are not exploited without authorization.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Wendy Schultz Senior Associate Intellectual Property Group

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

Enclosures:

Exhibit A — Representative List of 217 Infringing Titles (cross-referencing the Copyright Registration Summary Report prepared from Lexington IP Services, Inc. data)

cc: (via email)

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

This letter and any enclosures are confidential and may contain information protected by the attorney-client privilege, the work product doctrine, or other applicable privileges. If you are not the intended recipient, please notify the sender immediately and destroy all copies of this communication. Any unauthorized review, use, disclosure, or distribution of this communication is strictly prohibited.

Revenue Category	Amount (US$)
Subscription revenue attributable to Aurelius content	$22,400,000
Advertising revenue (AVOD tier) attributable to Aurelius content	$9,700,000
Sublicensing fees received from FAST channel operators (including Pacific Lantern)	$6,500,000
Total	$38,600,000

CALDERWOOD & HARKNESS LLP Attorneys at Law
1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Telephone: (310) 553-4800 Facsimile: (310) 553-4801
Writer's Direct Dial: (310) 553-4837 Writer's Facsimile: (310) 553-4899 Writer's Email: wschultz@calderwoodharkness.com
VIA INTERNATIONAL COURIER (Granite Harbor Enterprises — TRACKED/SIGNED) AND EMAIL
March 14, 2026
Pacific Lantern Digital Pty Ltd Level 18, One International Towers 100 Barangaroo Avenue Sydney, NSW 2000 Australia
Attn: General Counsel / Chief Executive Officer
Re: Unauthorized Distribution of Copyrighted Audiovisual Works Owned by Aurelius Global Media Group PLC — Demand for Immediate Takedown and Preservation of Records
Matter No. 1017-00003
Dear Sir or Madam:
I. Introduction and Identification of Counsel
This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated under the laws of England and Wales (Companies House Registration No. 08724561), with its principal office and headquarters located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius operates in the United States through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc., which maintains offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. Aurelius Media Americas, Inc. serves as the U.S.-based operational arm for Aurelius's distribution, licensing, and rights enforcement activities throughout the Americas region.
Aurelius is a global media and entertainment conglomerate listed on the Alternative Investment Market of the London Stock Exchange (AIM: AGLM). For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately US$2.36 billion at prevailing exchange rates), making it one of the largest independent media companies in the world. Aurelius's business activities span theatrical film production and distribution, scripted and unscripted television programming, digital content licensing, home entertainment, and global merchandising.
Aurelius owns a content library comprising more than 4,200 film and television titles, including internationally recognized and commercially significant properties. Among these are:
• The "Meridian" franchise, which comprises six feature films released between 2012 and 2024 and has earned a combined global box office of approximately US$1.43 billion, with extensive downstream licensing revenues in home entertainment, pay television, subscription video-on-demand, and merchandising;
• The "Iron Compass" series, a critically acclaimed and commercially successful dramatic television series spanning four seasons and forty-eight episodes, which averaged approximately 9.2 million viewers per episode in the United Kingdom during its initial broadcast run and has been licensed to broadcasters and streaming platforms in over seventy territories worldwide; and
• The "Thornfield" period drama catalog, a collection of twelve individually titled feature films and limited series that have collectively received seven British Academy of Film and Television Arts (BAFTA) awards and numerous other accolades, and which continue to generate significant licensing and syndication revenues globally.
We write to you in connection with the unauthorized exploitation by Pacific Lantern Digital Pty Ltd ("Pacific Lantern" or "your company") of copyrighted audiovisual works owned by Aurelius. The facts set forth below demonstrate that Pacific Lantern has been distributing a substantial volume of Aurelius-owned content without any license, consent, or authorization from Aurelius or any entity lawfully authorized to grant such rights. This letter constitutes a formal demand for immediate cessation and takedown of all infringing content, preservation of relevant records, and compliance with the additional requirements detailed herein.
II. Background — The Unauthorized Sublicensing Chain
Our investigation has uncovered a multi-layered unauthorized sublicensing scheme through which Aurelius's copyrighted content has been misappropriated and distributed without authorization. The relevant parties and the chain of unauthorized distribution are set forth below.
A. StreamNow Holdings, Inc. and the Infringing Platform
StreamNow Holdings, Inc. ("StreamNow") is a Delaware corporation (State of Delaware Division of Corporations File No. 7291843) with its principal offices located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a streaming "super-aggregator" platform—a digital distribution service that bundles and makes available content from multiple studios, independent distributors, and other content suppliers. StreamNow's platform is currently available to consumers in fourteen countries across North America, Europe, and the Asia-Pacific region.
StreamNow is a privately held company. Its majority equity ownership—approximately sixty-two percent (62%) on a fully diluted basis—is held by Pinnacle Ventures Fund III, LP, a venture capital fund. StreamNow's estimated consolidated revenue for the fiscal year ending December 31, 2025 was approximately US$312 million, derived from a combination of subscription fees, advertising revenue from its ad-supported tier, and sublicensing fees collected from downstream distribution partners.
Without any authorization from Aurelius—whether directly, through Aurelius Media Americas, Inc., or through any authorized agent—StreamNow ingested at least two hundred seventeen (217) Aurelius-owned audiovisual works into its platform and made those works available to its subscribers and through sublicensed distribution channels. The 217 unauthorized works comprise one hundred forty-two (142) feature films and seventy-five (75) television series encompassing a total of one thousand thirty-eight (1,038) individual episodes. The unauthorized exploitation of these works commenced on or about April 1, 2024, has continued for an approximate period of twenty-two (22) months through at least January 31, 2026, and is believed to be ongoing as of the date of this letter.
B. Meridian Digital Distributors, LLC — The Unauthorized Intermediary
StreamNow purportedly obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with a registered address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD represented itself as an authorized distributor of the Aurelius titles in question.
Our investigation has established that MDD's sole member and manager is Franklin Ogilvie. Mr. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc., where he was employed from approximately September 2017 through June 30, 2021. Mr. Ogilvie's employment with Aurelius Media Americas, Inc. was terminated effective June 30, 2021, following an internal investigation that substantiated concerns regarding Mr. Ogilvie's unauthorized access to and use of Aurelius's proprietary content management systems and licensing databases. In connection with his departure, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, a comprehensive non-competition covenant, a non-solicitation clause, and an explicit prohibition on the use, exploitation, reproduction, or distribution of any Aurelius intellectual property, including without limitation all audiovisual content, trademarks, trade secrets, and proprietary information.
Aurelius's records—including its centralized licensing database, board and management committee records, and authorized distributor registry—unequivocally confirm that Aurelius never granted MDD any license, sublicense, distribution authorization, agency appointment, or any other form of consent to exploit, distribute, or make available any Aurelius-owned content. MDD is not and has never been an authorized distributor, licensee, sublicensee, or agent of Aurelius for any purpose. Mr. Ogilvie had no authority, actual or apparent, to grant any rights in Aurelius content following (or indeed prior to) the termination of his employment.
Accordingly, any purported "Content Distribution Agreement" between MDD and StreamNow—which our investigation indicates was executed on or about March 15, 2024, and which purported to grant StreamNow rights to distribute the Aurelius titles identified therein—conveyed no rights whatsoever. MDD had no rights to grant, and StreamNow received nothing of value, as a matter of copyright law. The entire foundation of the purported sublicensing chain was fraudulent and void ab initio.
C. Pacific Lantern's Receipt of Unlawfully Sublicensed Content
StreamNow, in turn, sublicensed bundles of content—including the 217 Aurelius-owned works described above—to at least four third-party FAST (Free Ad-Supported Streaming Television) channel operators. Pacific Lantern Digital Pty Ltd is one of those four identified sublicensees. The other three identified FAST channel sublicensees are:
1. Brindoval Channel Networks, Inc., located in Dallas, Texas;
2. BrightLoop Media, LLC, located in Miami, Florida; and
3. Velvet Stream Partners, LP, located in Toronto, Ontario, Canada.
Pacific Lantern has been distributing Aurelius content through its FAST channels—making the works available to the public for streaming and viewing—without any authorization from, or license agreement with, Aurelius or any entity lawfully entitled to grant such authorization. Pacific Lantern has no direct, indirect, or derivative contractual relationship with Aurelius whatsoever, and Aurelius has never consented to Pacific Lantern's exploitation of its content.
The legal consequence of the facts set forth above is clear: because StreamNow itself had no valid rights to the Aurelius content—its only purported source of rights being MDD, which had no authority to grant any rights—StreamNow's sublicense to Pacific Lantern conveyed no valid rights to Pacific Lantern. It is a fundamental principle of both U.S. and international copyright law that a sublicensor cannot convey greater rights than it possesses (nemo dat quod non habet). Pacific Lantern's distribution of Aurelius content is therefore unauthorized, unlicensed, and constitutes actionable copyright infringement.
III. Aurelius's Copyrights in the Works at Issue
Aurelius, directly and through its wholly-owned subsidiary Aurelius Media Americas, Inc., is the exclusive owner of all United States and international copyrights in each of the 217 audiovisual works that Pacific Lantern has been distributing without authorization. The works at issue span a diverse range of Aurelius's content library and include, without limitation, titles from the "Meridian" franchise, the "Iron Compass" series, and the "Thornfield" period drama catalog, as well as numerous additional feature films, television series, and other audiovisual productions. A representative list of the 217 infringing titles is attached hereto as Exhibit A, which cross-references the Copyright Registration Summary Report prepared from the records of Lexington IP Services, Inc.
Of the 217 titles at issue:
• One hundred eighty-nine (189) works have valid, timely United States copyright registrations that were filed either within three months of the date of first publication of each respective work or prior to the commencement of infringement. These timely registrations qualify the works for the full range of remedies available under the United States Copyright Act, including statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), as well as recovery of full costs and reasonable attorneys' fees under 17 U.S.C. § 505.
• Twenty-eight (28) works have United States copyright registrations that were filed after the commencement of the infringing activity (i.e., registered between May 2024 and October 2025). While these registrations satisfy the jurisdictional prerequisite for filing suit under 17 U.S.C. § 411(a), they do not qualify for statutory damages or attorneys' fee awards under sections 412 and 504(c). Aurelius is, however, fully entitled to recover actual damages suffered and any profits of the infringer attributable to the infringement of these works under 17 U.S.C. § 504(b).
Verification of the registration status of all 217 works was completed on January 22, 2026, by Lexington IP Services, Inc., a nationally recognized intellectual property records and search firm, through a comprehensive search of the records of the United States Copyright Office. Lexington IP Services confirmed the validity of all registrations and the absence of any adverse claims, conflicting registrations, or title defects.
In addition, Aurelius's chain of title for all 217 works has been thoroughly reviewed and confirmed to be complete and without gaps. The chain of title documentation for each work, including original copyright assignment agreements, work-for-hire agreements, and certificates of registration, is maintained by Aurelius and is available for inspection as may be required in connection with any enforcement proceedings.
IV. Legal Basis — Copyright Infringement
Pacific Lantern's conduct constitutes copyright infringement under the United States Copyright Act, 17 U.S.C. §§ 101 et seq., and under applicable international copyright law. Specifically:
Pacific Lantern's unauthorized public performance, distribution, and reproduction of the 217 Aurelius-owned audiovisual works violates the exclusive rights of copyright owners under 17 U.S.C. § 106. Section 106 of the Copyright Act grants to the owner of a copyright the exclusive rights to do and to authorize any of the following: (1) to reproduce the copyrighted work in copies or phonorecords (§ 106(1)); (2) to prepare derivative works based upon the copyrighted work (§ 106(2)); (3) to distribute copies or phonorecords of the copyrighted work to the public by sale or other transfer of ownership, or by rental, lease, or lending (§ 106(3)); and (4) in the case of motion pictures and other audiovisual works, to perform the copyrighted work publicly (§ 106(4)). Pacific Lantern's activities—which include the ingestion, storage, streaming, and public display of Aurelius's copyrighted audiovisual works through its FAST channels—implicate each of these exclusive rights.
Such unauthorized acts constitute infringement under 17 U.S.C. § 501, 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."
Pacific Lantern cannot rely on StreamNow's purported sublicense as a defense to infringement. As set forth in detail above, StreamNow itself had no valid rights to sublicense the Aurelius content. The purported chain of rights traces back, in its entirety, to MDD, which had no authority whatsoever from Aurelius to license, distribute, or otherwise exploit any Aurelius-owned content. It is black-letter law that a sublicensor cannot convey greater rights than it possesses. See, e.g., Gardner v. Sterling Reach Partners LLC, 279 F.3d 774, 780 (9th Cir. 2002) (a party cannot convey rights in a copyrighted work that it does not hold). Because MDD had no rights, StreamNow acquired no rights from MDD, and Pacific Lantern, in turn, acquired no rights from StreamNow. Pacific Lantern's purported sublicense is a legal nullity.
Moreover, StreamNow does not qualify for the safe harbor protections of Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512. StreamNow does not function as a passive hosting or conduit service within the meaning of § 512(a) through (d). Rather, StreamNow actively curates, ingests, licenses, and monetizes the content on its platform—exercising editorial control over the selection and arrangement of content offerings, entering into affirmative sublicense agreements with downstream distributors, and deriving direct financial benefit from the exploitation of the content. StreamNow's active involvement in the content licensing chain places it squarely outside the scope of the DMCA safe harbor provisions. StreamNow's inability to avail itself of safe harbor protection further underscores the invalidity of any downstream sublicense that StreamNow purported to grant, including its sublicense to Pacific Lantern.
Aurelius's investigation into the facts underlying this demand has been supported by extensive digital forensic analysis performed by CipherTrace Analytics, LLC, a leading digital forensics and e-discovery firm retained by Calderwood & Harkness for this purpose. The engagement was led by Dr. Nathan Frey, a digital forensics expert with over fifteen years of experience in online content identification and rights enforcement investigations. CipherTrace's forensic analysis confirmed the presence of all 217 Aurelius-owned titles on the StreamNow platform and on each of the downstream sublicensed channels, including Pacific Lantern's FAST channels. CipherTrace's analysis employed proprietary audio-visual fingerprinting technology, metadata extraction, and comparative analysis against Aurelius's master content registry to verify the identity and provenance of each infringing work.
V. Revenue and Damages Context
The scale of the unauthorized exploitation at issue is substantial, and Aurelius has suffered—and continues to suffer—significant economic harm as a result.
CipherTrace Analytics, LLC's forensic analysis attributes a total of approximately US$38.6 million in revenue to StreamNow's unauthorized exploitation of Aurelius content over the twenty-two-month infringement period (April 1, 2024 through January 31, 2026). This revenue is broken down as follows:
These figures represent the revenues directly attributable to the Aurelius titles based on viewership data, content engagement metrics, and sublicensing fee allocation analyses performed by CipherTrace.
In addition, Aurelius engaged Hargrove Economic Consulting Group, LLC, a nationally recognized economic consulting firm specializing in intellectual property damages quantification, to prepare a preliminary damages estimate. The engagement was led by Dr. Elena Vasquez, a Ph.D. economist with extensive experience in entertainment industry damages analyses. Dr. Vasquez's preliminary assessment estimates net recoverable damages of approximately US$41.3 million, based on a combination of:
• Actual damages in the form of lost licensing revenue of approximately US$14.2 million, representing the fair market value licensing fees that Aurelius would have received had the 217 works been licensed through authorized channels during the relevant period; and
• Infringer's profits attributable to the unauthorized exploitation of Aurelius content, with appropriate apportionment under 17 U.S.C. § 504(b) to exclude profits attributable to non-infringing content and to account for the infringer's deductible expenses.
As an alternative measure of damages, Aurelius may elect to recover statutory damages under 17 U.S.C. § 504(c)(2). For the 189 works with timely copyright registrations, Aurelius is entitled to seek statutory damages of up to $150,000 per work for willful infringement. If statutory damages are elected for all eligible works, Aurelius's potential statutory damages recovery would be up to US$28,350,000 for those 189 works alone. Combined with actual damages and profits for the remaining 28 works, Aurelius's total potential recovery under a statutory damages theory could reach or exceed US$32,550,000 (calculated as 217 works × $150,000, though statutory damages are available only for the 189 timely-registered works; the balance would be recovered as actual damages and profits).
Importantly, Pacific Lantern's own revenues derived from distributing Aurelius content through its FAST channels may be subject to disgorgement as part of the infringer's profits recoverable under 17 U.S.C. § 504(b). Pacific Lantern bears the burden of proving any deductible expenses and any elements of profit attributable to factors other than the copyrighted work. Aurelius intends to pursue full recovery of all profits earned by Pacific Lantern from the unauthorized exploitation of the 217 Aurelius titles.
Aurelius expressly reserves all rights to pursue damages and profits attributable to Pacific Lantern's unauthorized exploitation, whether in a standalone proceeding or as part of broader enforcement actions against StreamNow, MDD, and other parties in the unauthorized distribution chain.
VI. Demands
In light of the foregoing, Aurelius, through undersigned counsel, hereby makes the following demands upon Pacific Lantern Digital Pty Ltd:
A. Immediate Cessation and Takedown
Aurelius demands that Pacific Lantern immediately cease all reproduction, distribution, public performance, public display, digital transmission, and any other exploitation of each and every one of the 217 Aurelius-owned audiovisual works identified in Exhibit A hereto, including but not limited to all titles from the "Meridian" franchise, the "Iron Compass" series, and the "Thornfield" period drama catalog, and all other Aurelius titles that may have been made available through Pacific Lantern's channels or services.
Pacific Lantern must remove all Aurelius content from its FAST channels, servers, content delivery networks ("CDNs"), caching systems, backup systems, and any other distribution platforms, storage systems, or media within its custody or control. This removal must be comprehensive and must include the deletion or quarantine of all copies of Aurelius content, including any transcoded, reformatted, or derivative versions, from all systems and networks operated by or on behalf of Pacific Lantern.
B. Confirmation of Takedown
Aurelius demands that Pacific Lantern provide written confirmation, executed by an authorized officer or representative of Pacific Lantern, certifying that all Aurelius content has been fully and permanently removed from Pacific Lantern's channels, systems, servers, CDNs, and all other platforms and storage media within Pacific Lantern's custody or control. Such written confirmation must be delivered to the undersigned counsel within ten (10) business days of the date of this letter—that is, by no later than March 28, 2026.
The written confirmation should:
(a) identify by title and registration number each of the 217 works that have been removed;
(b) certify that no copies, in any format, of any of the identified works remain on any system, server, CDN, backup system, or other storage medium within Pacific Lantern's custody or control;
(c) identify any third-party service providers (including but not limited to CDN providers, cloud hosting providers, and technology partners) through which Pacific Lantern distributed or stored Aurelius content, and confirm that such providers have also been directed to remove all Aurelius content; and
(d) be signed under penalty of perjury or, at a minimum, under a certification that the statements made therein are true, complete, and accurate to the best of the signatory's knowledge and belief.
C. Preservation of Records
Aurelius hereby places Pacific Lantern on formal notice of its obligation to immediately preserve—and to refrain from destroying, deleting, altering, concealing, or otherwise disposing of—all documents, data, and records relating to the matters described in this letter. This preservation obligation includes, without limitation, the following categories of materials:
(a) All sublicense agreements, content distribution agreements, and any other contracts or arrangements between Pacific Lantern and StreamNow Holdings, Inc. (or any affiliate or agent thereof), including all amendments, addenda, schedules, exhibits, side letters, and related correspondence;
(b) All content received from or through StreamNow Holdings, Inc. (or any affiliate or agent thereof), including all delivery records, technical specifications, asset manifests, content identification metadata, watermark data, and digital rights management information;
(c) All revenues, viewership data, audience metrics, advertising revenue, subscription revenue, and any other financial records or reports relating to the distribution of any Aurelius-owned content through Pacific Lantern's channels, platforms, or services, whether generated internally or received from third parties;
(d) All internal and external communications—whether by email, instant message, text message, video conference, telephone, or any other medium—regarding the acquisition, licensing, distribution, monetization, or removal of any Aurelius-owned content, including but not limited to communications with or about StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie, or any other intermediary, broker, or third party; and
(e) All documents, data, and records relating to Pacific Lantern's due diligence or investigation (if any) into the provenance, ownership, or authorization of the content received from StreamNow, including any representations or warranties received from StreamNow regarding its rights to the content.
Pacific Lantern is advised that the failure to preserve documents and data in accordance with this notice may result in adverse inference instructions, evidentiary sanctions, and other penalties in any subsequent litigation. Aurelius will seek the full range of available sanctions against any party that fails to comply with its preservation obligations.
D. Accounting of Revenues
Aurelius requests that Pacific Lantern provide a full and complete accounting of all revenues—including but not limited to advertising revenue, subscription revenue, sublicensing fees, carriage fees, and any other income or consideration of any kind—derived from the distribution of the 217 Aurelius titles (and any other Aurelius-owned content) through Pacific Lantern's FAST channels, platforms, or other distribution services. This accounting should cover the entire period during which Pacific Lantern distributed any Aurelius content, and should be broken down by title, revenue category, and time period (monthly or quarterly, as available).
Aurelius requests that this accounting be provided within the same ten (10) business day period specified above (i.e., by no later than March 28, 2026), or, if additional time is reasonably required to compile the accounting, that Pacific Lantern communicate a specific and reasonable timeline for delivery of the accounting within the ten-business-day response period.
VII. Reservation of Rights
Aurelius expressly reserves all rights and remedies available to it at law and in equity, whether under United States federal or state law, Australian law, or the laws of any other applicable jurisdiction, including but not limited to:
(a) Claims for direct copyright infringement under 17 U.S.C. §§ 106 and 501;
(b) Claims for contributory copyright infringement and/or vicarious copyright infringement;
(c) Recovery of actual damages suffered by Aurelius as a result of the unauthorized exploitation of its copyrighted works, including lost licensing revenue and any other compensable harm;
(d) Recovery of infringer's profits attributable to the infringement, including profits earned by Pacific Lantern from the distribution of Aurelius content through its FAST channels;
(e) Statutory damages of up to $150,000 per work for willful infringement under 17 U.S.C. § 504(c)(2), with respect to all eligible works;
(f) Recovery of full costs and reasonable attorneys' fees under 17 U.S.C. § 505;
(g) Injunctive relief, including temporary restraining orders, preliminary injunctions, and permanent injunctions, to prevent any further unauthorized exploitation of Aurelius content;
(h) Any applicable claims under the Copyright Act 1968 (Cth) of Australia, or under any other foreign copyright laws, to the extent applicable to Pacific Lantern's activities; and
(i) Any and all other claims, remedies, and relief to which Aurelius may be entitled.
Nothing in this letter shall be construed as a waiver, release, or limitation of any of Aurelius's rights, claims, or remedies, whether or not expressly referenced herein. Aurelius's willingness to engage with Pacific Lantern at this pre-litigation stage, and its provision of an opportunity for Pacific Lantern to comply with the demands set forth above, should not be construed as an acceptance of any delay in enforcement, a limitation on the scope of Aurelius's claims, or an acknowledgment that Pacific Lantern's conduct is excusable or mitigated in any respect.
For your information, Aurelius has already served concurrent formal cease-and-desist and pre-suit demand letters on the following parties:
• StreamNow Holdings, Inc. (attention: Tobias Rennert, General Counsel);
• Meridian Digital Distributors, LLC and Franklin Ogilvie individually; and
• The three other identified FAST channel sublicensees: Brindoval Channel Networks, Inc., BrightLoop Media, LLC, and Velvet Stream Partners, LP.
Aurelius is pursuing coordinated enforcement action against all parties in the unauthorized distribution chain and will take whatever steps are necessary to protect its rights and recover all available damages and relief.
VIII. Consequences of Non-Compliance
Pacific Lantern is hereby placed on notice that if it fails to comply with the demands set forth in this letter within the specified timeframes, Aurelius will pursue all available legal remedies without further notice or delay. Such remedies include, but are not limited to:
• Filing suit against Pacific Lantern for copyright infringement in the United States District Court for the Central District of California, Los Angeles Division, and/or in any other court of competent jurisdiction, including courts in Australia or other jurisdictions where Pacific Lantern operates or distributes content;
• Seeking emergency injunctive relief, including temporary restraining orders and preliminary injunctions, to compel the immediate removal of all Aurelius content from Pacific Lantern's channels and systems;
• Seeking the maximum available statutory damages, actual damages, infringer's profits, attorneys' fees, and costs; and
• Pursuing any additional claims and remedies that may be available under applicable law.
Pacific Lantern is further advised that its continued distribution of Aurelius content after receipt of this notice will be treated as strong evidence of willful copyright infringement, exposing Pacific Lantern to enhanced statutory damages of up to $150,000 per work under 17 U.S.C. § 504(c)(2), as well as other enhanced penalties and remedies. Willfulness is a factual determination that courts consider in assessing damages, and continued exploitation of copyrighted works after receipt of a detailed takedown demand from the rights holder is a significant factor weighing in favor of a willfulness finding. See, e.g., Columbia Pictures Television, Inc. v. Krypton Broad. of Birmingham, Inc., 259 F.3d 1186, 1194 (9th Cir. 2001).
Aurelius has retained CipherTrace Analytics, LLC for ongoing forensic monitoring of Pacific Lantern's FAST channels and distribution platforms. Any continued distribution of Aurelius content after the date of this letter will be documented and preserved for use in any subsequent enforcement proceedings. Aurelius will also seek to recover any additional damages, profits, and costs arising from any post-notice infringement.
IX. Contact and Response Instructions
All responses, communications, and correspondence regarding this matter should be directed to:
Wendy Schultz Senior Associate, intellectual Property Group Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Telephone: (310) 553-4837 Facsimile: (310) 553-4899
Email: wschultz@calderwoodharkness.com
Please reference Matter No. 1017-00003 in all correspondence relating to this matter.
We strongly encourage Pacific Lantern to engage experienced copyright counsel promptly and to respond to this letter within the timeframes set forth above. Aurelius is prepared to discuss an orderly resolution of this matter, but will not hesitate to initiate litigation if compliance is not forthcoming.
We trust that Pacific Lantern will treat this matter with the urgency it requires and will act promptly to comply with the demands set forth herein. Aurelius takes the protection of its intellectual property rights extremely seriously and will pursue all necessary measures to ensure that its copyrighted works are not exploited without authorization.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Wendy Schultz Senior Associate Intellectual Property Group
Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Enclosures:
Exhibit A — Representative List of 217 Infringing Titles (cross-referencing the Copyright Registration Summary Report prepared from Lexington IP Services, Inc. data)
cc: (via email)
Marcus Delgado, Partner, Calderwood & Harkness LLP Catherine Bloom, Partner, Calderwood & Harkness LLP Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Global Media Group PLC
This letter and any enclosures are confidential and may contain information protected by the attorney-client privilege, the work product doctrine, or other applicable privileges. If you are not the intended recipient, please notify the sender immediately and destroy all copies of this communication. Any unauthorized review, use, disclosure, or distribution of this communication is strictly prohibited.
Revenue Category | Amount (US$)
Subscription revenue attributable to Aurelius content | $22,400,000
Advertising revenue (AVOD tier) attributable to Aurelius content | $9,700,000
Sublicensing fees received from FAST channel operators (including Pacific Lantern) | $6,500,000
Total | $38,600,000

CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP

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