CALDERWOOD & HARKNESS LLP Attorneys at Law 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
Telephone: (310) 556-8200 Facsimile: (310) 556-8201 www.calderwoodharkness.com
Wendy Schultz Senior Associate, intellectual Property Direct Dial: (310) 556-8247
Email: wschultz@calderwoodharkness.com
March 14, 2026
VIA CERTIFIED MAIL / RETURN RECEIPT REQUESTED AND VIA EMAIL
Velvet Stream Partners, LP
Attn: General Counsel / Managing Partner
200 Bay Street, Suite 2600 Toronto, ON M5J 2J2 Canada
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
To Whom It May Concern:
We write on behalf of our client, 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 offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Calderwood & Harkness LLP has been retained by Aurelius to represent it in all matters arising from the unauthorized distribution, reproduction, and public performance of Aurelius-owned copyrighted audiovisual content. Aurelius operates its U.S. operations through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. Aurelius is listed on the London Stock Exchange's AIM market (AIM: AGLM) and is a leading global media and entertainment conglomerate whose content library encompasses over 4,200 feature film and television titles spanning multiple genres, languages, and territories.
This letter constitutes a formal demand that Velvet Stream Partners, LP ("Velvet Stream") immediately cease all unauthorized distribution and public performance of Aurelius-owned copyrighted audiovisual works through Velvet Stream's FAST (Free Ad-Supported Streaming Television) channels and all other platforms, and that Velvet Stream take each of the additional actions described in detail below. Aurelius is prepared to take all steps necessary—including, without limitation, the commencement of litigation—to protect its intellectual property rights should Velvet Stream fail to comply with the demands set forth herein.
I. AURELIUS'S COPYRIGHTS AND PROPRIETARY RIGHTS
Aurelius is the owner or exclusive controller of the United States and worldwide copyrights in a vast and commercially significant catalog of audiovisual works, including feature films and television series produced, acquired, and distributed by Aurelius and its subsidiaries over the past three decades. As a result of decades of investment in creative development, production, and strategic acquisition, Aurelius's content library is among the most valuable in the global entertainment industry.
At issue in this matter are 217 individual titles, consisting of 142 feature films and 75 television series comprising a total of 1,038 episodes. All 217 of these titles have been registered with the United States Copyright Office. Of these, 189 titles hold timely registrations under 17 U.S.C. § 412, entitling Aurelius to the full range of remedies available under the Copyright Act, including statutory damages and attorneys' fees. A complete listing of the 217 titles, together with their corresponding U.S. Copyright Office registration numbers, registration dates, and production details, is set forth in the Copyright Registration Summary Report prepared by Lexington IP Services, Inc., which is enclosed with this letter as Exhibit A.
Among the affected titles are several of Aurelius's most commercially and critically acclaimed franchises and works, including but not limited to the following:
• The "Meridian" Franchise: A series of six (6) feature films released between 2014 and 2023, with a combined global theatrical box office of approximately $1.43 billion. The Meridian franchise is one of Aurelius's flagship intellectual properties and a cornerstone of its feature film slate, generating substantial ongoing revenue through theatrical distribution, home entertainment, pay television licensing, and authorized streaming arrangements worldwide.
• The "Iron Compass" Series: A critically acclaimed television series spanning four (4) seasons and forty-eight (48) episodes, which averaged 9.2 million viewers per episode in the United Kingdom during its original broadcast run. The Iron Compass series has been licensed for broadcast and streaming distribution in over 60 territories and remains one of the most valuable serialized properties in Aurelius's catalog.
• The "Thornfield" Period Drama Catalog: A collection of twelve (12) period drama titles—including both feature films and limited television series—that have collectively received seven (7) BAFTA Awards and numerous other industry accolades. The Thornfield catalog is widely regarded as a benchmark of prestige programming and continues to generate significant licensing revenue in the United States and internationally.
Aurelius holds all exclusive rights in and to these works as provided under Section 106 of the United States Copyright Act, 17 U.S.C. § 106, including without limitation the exclusive rights to reproduce the copyrighted works, to prepare derivative works, to distribute copies of the copyrighted works to the public by sale or other transfer of ownership or by rental, lease, or lending, and to perform the copyrighted works publicly, including by means of digital audio transmission and digital streaming. These rights have not been licensed, assigned, or otherwise conveyed to Velvet Stream, StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, or any entity in the distribution chain through which Velvet Stream purports to have obtained authorization to exploit Aurelius content.
II. VELVET STREAM'S UNAUTHORIZED DISTRIBUTION OF AURELIUS CONTENT
Calderwood & Harkness's investigation, supported by detailed forensic analysis conducted by CipherTrace Analytics, LLC ("CipherTrace"), a digital media forensics firm retained by Aurelius in connection with this matter, has confirmed that Velvet Stream Partners, LP is currently distributing and publicly performing Aurelius-owned audiovisual works through its FAST channel operations without any authorization from Aurelius, AMA, or any authorized representative of either entity. CipherTrace's analysis included the identification and verification of Aurelius content across Velvet Stream's publicly accessible FAST channels through automated content fingerprinting, manual review of metadata and programming schedules, and comparison against Aurelius's proprietary content identification database.
Our investigation has determined that Velvet Stream obtained the Aurelius content through a sublicense or content distribution arrangement with StreamNow Holdings, Inc. ("StreamNow"), a Delaware corporation headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow purported to sublicense bundles of audiovisual content, including the 217 Aurelius titles at issue, to Velvet Stream and to at least three (3) other third-party FAST channel operators: Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; and Pacific Lantern Digital Pty Ltd. Aurelius has not authorized any of these entities to distribute, reproduce, or publicly perform any Aurelius-owned content, and none of them possesses any valid license or sublicense to do so.
Based on the information currently available to Aurelius, the unauthorized distribution and public performance of the 217 Aurelius titles through Velvet Stream's FAST channels has been ongoing since approximately April 1, 2024, representing a continuous period of unauthorized exploitation of approximately twenty-two (22) months through January 31, 2026. It is possible, and indeed likely, that additional unauthorized uses not yet identified have occurred during this period or are continuing as of the date of this letter.
III. STREAMNOW'S LACK OF AUTHORIZATION — THE MDD CHAIN
Calderwood & Harkness's investigation has further established that StreamNow's purported rights to the Aurelius content are entirely without foundation. StreamNow claims to have obtained distribution rights to the Aurelius catalog through a so-called "Content Distribution Agreement" allegedly executed on or about March 15, 2024, with Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430). MDD's sole member and manager is Franklin Ogilvie.
Franklin Ogilvie is 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 conducted by Aurelius's compliance and information security teams into unauthorized access to Aurelius's content management systems and licensing databases. The circumstances of Mr. Ogilvie's departure are the subject of separate proceedings, and Aurelius reserves all rights and claims arising from Mr. Ogilvie's conduct during and after his employment.
Mr. Ogilvie's separation agreement with AMA, dated June 30, 2021, includes, among other provisions, a non-compete clause, a non-solicitation clause, and an explicit and unambiguous prohibition on the use, disclosure, or exploitation of any Aurelius intellectual property following the termination of his employment. Mr. Ogilvie was never authorized to license, sublicense, distribute, or otherwise exploit any Aurelius-owned content during his employment, and he certainly possessed no such authority after his separation from the company.
Aurelius has never granted MDD any license, sublicense, distribution authority, or other rights of any kind whatsoever over any Aurelius-owned content. MDD is not and has never been an authorized distributor, agent, licensee, or representative of Aurelius or AMA. Aurelius has never entered into any agreement, arrangement, or understanding with MDD, Franklin Ogilvie (in his individual capacity or otherwise), or any entity affiliated with either of them, relating to the distribution or exploitation of any Aurelius intellectual property. MDD had no rights to convey, and any purported agreement between MDD and StreamNow with respect to Aurelius content is, accordingly, void and without legal effect.
StreamNow's purported sublicense from MDD is therefore a nullity. StreamNow could not have obtained any valid rights to the Aurelius content from MDD because MDD itself possessed no such rights. Under the well-established principle of nemo dat quod non habet—one cannot give what one does not have—StreamNow's purported grant of sublicense rights to Velvet Stream with respect to Aurelius content is equally void and conveys no rights whatsoever. Velvet Stream does not possess, and has never possessed, any lawful authority to reproduce, distribute, or publicly perform any Aurelius-owned audiovisual work.
The deficiency in the chain of title is fundamental and incurable. No amount of reliance on StreamNow's representations can create rights where none existed. Velvet Stream's continued exploitation of the Aurelius content is, and has at all relevant times been, unauthorized and unlawful.
IV. LEGAL CLAIMS AND LIABILITY EXPOSURE
Velvet Stream's ongoing and unauthorized reproduction, distribution, and public performance of the 217 Aurelius titles through its FAST channels constitutes copyright infringement in violation of 17 U.S.C. §§ 106 and 501 of the United States Copyright Act. Each unauthorized reproduction, distribution, and public performance of each copyrighted work constitutes a separate act of infringement, and Velvet Stream's liability is compounded by the scale, duration, and commercial nature of the unauthorized exploitation.
Statutory Damages. For the 189 titles that hold timely U.S. copyright registrations within the meaning of 17 U.S.C. § 412, Aurelius is entitled to elect statutory damages under 17 U.S.C. § 504(c). Where, as here, the infringement is willful—or, at minimum, the infringer had reason to know that its use was unauthorized—the Copyright Act permits the Court to award enhanced statutory damages of up to $150,000 per work infringed under 17 U.S.C. § 504(c)(2). The potential statutory damages exposure for the 189 timely-registered titles alone is therefore in excess of $28,350,000, exclusive of additional damages, fees, and costs.
Actual Damages and Profits. For all 217 titles, Aurelius is further entitled to recover its actual damages suffered as a result of the infringement, as well as any profits of Velvet Stream attributable to the infringement that are not already accounted for in the computation of actual damages, pursuant to 17 U.S.C. § 504(b). Given the scale and duration of the unauthorized distribution—22 months across multiple FAST channels—the actual damages and disgorgement of profits are expected to be substantial.
Attorneys' Fees and Costs. For the 189 timely-registered titles, Aurelius is also entitled to seek an award of its reasonable attorneys' fees and full costs incurred in connection with any enforcement action, pursuant to 17 U.S.C. § 505.
Injunctive Relief. Aurelius is entitled to seek, and intends to seek if necessary, preliminary and permanent injunctive relief under 17 U.S.C. § 502, enjoining Velvet Stream from any further reproduction, distribution, or public performance of any Aurelius-owned content.
Aurelius expressly reserves all rights and claims against all parties in the chain of unauthorized distribution, including but not limited to StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie individually, Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Pacific Lantern Digital Pty Ltd, and any other parties found to have participated in or facilitated the unauthorized exploitation of Aurelius's copyrighted works. Nothing in this letter shall be construed as an election of remedies or a limitation on Aurelius's right to pursue claims against any or all responsible parties.
Velvet Stream is advised that its liability exposure will only increase with each additional day of unauthorized exploitation. Each day on which Aurelius content continues to be distributed or performed through Velvet Stream's channels constitutes additional acts of infringement, additional accrual of damages, and further evidence of willfulness. It is in Velvet Stream's clear interest to take immediate corrective action.
V. DEMANDS
In light of the foregoing, Aurelius hereby makes the following demands:
1. Immediate Cessation and Removal of All Aurelius Content
Aurelius demands that Velvet Stream immediately cease all reproduction, distribution, and public performance of all 217 Aurelius-owned audiovisual works identified in Exhibit A hereto, as well as any other Aurelius content not yet identified that may be present on Velvet Stream's platforms, across all Velvet Stream FAST channels and platforms, in all territories worldwide, effective immediately upon receipt of this letter.
All Aurelius content must be permanently removed from Velvet Stream's servers, content delivery networks (CDNs), cloud storage environments, caching systems, and any other storage, distribution, or delivery systems operated by, on behalf of, or accessible to Velvet Stream. This includes, without limitation, the removal of all encoded, transcoded, and packaged versions of any Aurelius content, all associated metadata, promotional materials, thumbnails, trailers, and any other materials derived from or incorporating Aurelius content.
Confirmation of complete takedown must be provided to Calderwood & Harkness LLP in writing within ten (10) business days of the date of this letter—that is, no later than March 28, 2026. Such confirmation must include a written certification from an authorized officer or representative of Velvet Stream that all Aurelius content has been permanently removed from all Velvet Stream systems and that no further distribution or performance of any Aurelius content is occurring or will occur.
2. Preservation of Records
Aurelius demands that Velvet Stream immediately implement a litigation hold and preserve all documents, communications, and electronically stored information ("ESI") relating to the matters described in this letter. This obligation extends to, but is not limited to, the following categories of records:
(a) All agreements, contracts, sublicenses, content distribution agreements, amendments, side letters, term sheets, and any other documents evidencing or relating to the arrangement between Velvet Stream and StreamNow Holdings, Inc. for the licensing or distribution of audiovisual content, including but not limited to any agreements specifically referencing Aurelius content;
(b) All records relating to any Aurelius content received, ingested, stored, cataloged, processed, distributed, transmitted, or performed by Velvet Stream, including without limitation ingest logs, content manifests, digital asset management records, encoding and transcoding records, programming schedules, and channel playlists;
(c) All revenue records, viewership data, advertising impression data, CPM rates, advertising revenue, subscription revenue (if any), and all other financial records attributable to or associated with the distribution and/or performance of any Aurelius content through Velvet Stream's channels during the entire period of unauthorized use;
(d) All communications—including but not limited to emails, text messages, instant messages, Meridian Solutions or Teams messages, letters, memoranda, meeting notes, call logs, and any other form of communication—between or among Velvet Stream and StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Franklin Ogilvie, or any other party, to the extent such communications relate in any way to Aurelius content, the licensing or distribution thereof, or the rights chain described herein; and
(e) All internal communications, reports, memoranda, analyses, and other documents created by or on behalf of Velvet Stream relating to its due diligence (or lack thereof) with respect to the rights chain for the Aurelius content, including any legal opinions, title reports, or rights verifications obtained in connection with the StreamNow sublicense.
Velvet Stream must not delete, alter, destroy, overwrite, or otherwise modify any of the foregoing records. Any spoliation of evidence, whether intentional or resulting from a failure to implement adequate preservation measures, will be treated with the utmost seriousness in any subsequent judicial proceedings. Aurelius will not hesitate to seek sanctions, adverse inference instructions, and all other remedies available under applicable law in the event that any relevant evidence is lost or destroyed.
3. Accounting. Aurelius further requests that Velvet Stream provide a full and complete accounting of all revenues, viewership data, advertising impressions, and other financial metrics attributable to the distribution and performance of Aurelius content through Velvet Stream's channels during the entire period of unauthorized use, from approximately April 1, 2024, through the date on which all Aurelius content is removed from Velvet Stream's platforms. This accounting should include, at a minimum, the following:
(a) Total gross and net revenue generated from the distribution and/or performance of each Aurelius title, broken down by title, territory, and time period;
(b) Total advertising impressions served in connection with each Aurelius title, together with applicable CPM rates and total advertising revenue attributable to each title;
(c) Total viewership and streaming hours for each Aurelius title, broken down by title, territory, and time period; and
(d) Identification of all third parties (including advertisers, advertising networks, programmatic platforms, and any other entities) that purchased advertising inventory served in connection with or adjacent to Aurelius content.
This accounting information is necessary for Aurelius to assess its damages and is a reasonable request given the circumstances. Aurelius reserves the right to seek formal discovery of this information in any judicial proceeding.
VI. RESERVATION OF RIGHTS
This letter is not intended to be, and shall not be construed as, a waiver of any of Aurelius's rights, remedies, or defenses, all of which are expressly reserved in their entirety. Without limiting the generality of the foregoing, Aurelius expressly reserves:
(a) The right to pursue all available legal remedies, including but not limited to claims for copyright infringement, contributory and vicarious copyright infringement, statutory and actual damages, disgorgement of profits, preliminary and permanent injunctive relief, impoundment of infringing articles and materials, and recovery of attorneys' fees and costs, against Velvet Stream and all other responsible parties;
(b) The right to add Velvet Stream Partners, LP as a named defendant in any litigation commenced in connection with this matter, including an action that is currently being prepared for filing in the United States District Court for the Central District of California; and
(c) The right to assert any and all additional claims, causes of action, and theories of liability arising from Velvet Stream's conduct, whether now known or hereafter discovered.
Nothing in this letter, and no action or failure to act on the part of Aurelius or its counsel, shall constitute or be deemed to constitute a waiver, relinquishment, or limitation of any right, remedy, or claim, and Aurelius expressly disclaims any such construction.
VII. RESPONSE DEADLINE AND CONTACT INFORMATION
Velvet Stream is directed to confirm in writing that all Aurelius content has been permanently removed from its platforms, and to respond substantively to the demands set forth herein, within ten (10) business days of the date of this letter—that is, no later than March 28, 2026.
All responses, confirmations, and other communications relating to this matter 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 Direct Dial: (310) 556-8247
Email: wschultz@calderwoodharkness.com
Please reference Matter No. 1017-00003 in all correspondence.
VIII. CLOSING
Aurelius trusts that Velvet Stream will act promptly and in good faith to address the serious matters raised in this letter, and that Velvet Stream will take immediate steps to comply with each of the demands set forth above. The unauthorized exploitation of Aurelius's valuable copyrighted content has been ongoing for nearly two years, and further delay in remedying the situation is neither acceptable nor defensible.
Please be advised that failure to comply with the demands set forth herein will leave Aurelius no alternative but to pursue all available legal remedies, including the immediate commencement of litigation, without further notice to Velvet Stream. Aurelius is fully prepared to take such action and will not hesitate to do so if a satisfactory resolution is not achieved within the timeframe specified above.
We look forward to your prompt response.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Wendy Schultz Senior Associate, intellectual Property 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Direct Dial: (310) 556-8247
Email: wschultz@calderwoodharkness.com
Enclosure:
Exhibit A — List of Aurelius Titles at Issue (217-Title Catalog), cross-referencing the Copyright Registration Summary Report prepared by Lexington IP Services, Inc.
cc:
Marcus Delgado, Partner, Calderwood & Harkness LLP (via email) Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC (via email)