1017-00003 · Aurelius Global Media Group · Engagement & Administrative

conflict-check-memorandum.docx DOCUMENT Litigation

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MEMORANDUM — PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT

CALDERWOOD & HARKNESS LLP

Los Angeles Office 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067

This memorandum is protected by the attorney-client privilege and constitutes attorney work product. It is intended solely for the use of the named recipients. Any dissemination, distribution, or copying of this memorandum or any portion thereof is strictly prohibited without the prior written consent of the General Counsel's Office of Calderwood & Harkness LLP.

I. Purpose

This memorandum documents the results of the firm's conflict-of-interest check conducted in connection with the proposed engagement of Calderwood & Harkness LLP ("C&H" or the "Firm") by Aurelius Global Media Group PLC ("Aurelius" or "AGMG") for pre-suit copyright infringement assessment and enforcement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and related parties (collectively, the "Proposed Engagement").

The conflict check was initiated on January 16, 2026, following Marcus Delgado's initial consultation with Fiona Hartwell, General Counsel of Aurelius, which took place on January 15, 2026, at the Firm's Los Angeles office. During that consultation, Ms. Hartwell provided preliminary information regarding the identities of the parties likely to be involved in the matter, the nature of the anticipated claims, and the scope of legal services Aurelius seeks to retain C&H to perform. Supplemental searches were subsequently conducted on January 30, 2026 and February 7, 2026 to account for additional parties identified during the course of the intake process, including potential additional adverse parties, StreamNow's outside counsel, StreamNow's investor, and proposed expert consultants.

All results were reviewed and finalized as of the date of this memorandum, February 10, 2026. In accordance with Calderwood & Harkness's Conflicts of Interest Policy (Firm Policy No. 2019-COI-003, as amended October 1, 2024) and applicable rules of professional conduct — including, without limitation, the California Rules of Professional Conduct, Rules 1.7 (Conflict of Interest: Current Clients) and 1.9 (Duties to Former Clients) — clearance of this conflict check is required before the engagement can be formally opened and an engagement letter transmitted to the prospective client.

II. Proposed Engagement Summary

The following summarizes the key details of the Proposed Engagement:

Client:

Aurelius Global Media Group PLC, a public limited company incorporated in England and Wales under the Companies Act 2006, Companies House Registration No. 08724561, with its principal offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius's American Depositary Receipts ("ADRs") are traded over-the-counter ("OTC") in the United States. Aurelius's ordinary shares are listed on the London Stock Exchange's Alternative Investment Market under the ticker symbol AIM: AGLM. Aurelius is a diversified global media conglomerate with operations spanning film and television production, music publishing, digital content distribution, and live entertainment across Europe, the Americas, and the Asia-Pacific region.

U.S. Subsidiary:

Aurelius Media Americas, Inc. ("AMA"), a wholly-owned Delaware subsidiary of Aurelius Global Media Group PLC, with its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as the primary U.S. operating entity for Aurelius's content licensing and distribution activities in North America and manages the copyright registrations at issue in this matter through the U.S. Copyright Office.

Client Contact:

Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell has been designated by the client as the primary point of contact for all matters related to this engagement and has represented that she possesses the authority to retain outside counsel on behalf of Aurelius and its subsidiaries for purposes of this matter.

Nature of Matter:

Pre-suit assessment, demand, and potential litigation for copyright infringement under 17 U.S.C. §§ 106 and 501 (exclusive rights of copyright owners and infringement of copyright, respectively), together with supplemental state law claims under the California Unfair Competition Law, Cal. Bus. & Prof. Code § 17200 et seq. The claims arise from StreamNow's alleged unauthorized reproduction, distribution, and public performance of 217 Aurelius-owned audiovisual works — including feature-length films, episodic television series, and short-form documentary content — over an approximately 22-month period spanning from on or about April 1, 2024 through January 31, 2026. Preliminary damages have been estimated at $41.3 million by Hargrove Economic Consulting Group, LLC, based on a combination of actual damages and profits attributable to the infringement, with an alternative statutory damages analysis reserved. The matter may also involve secondary liability theories directed at MDD and its principal, Franklin Ogilvie, as well as potential claims against downstream sublicensees who received and publicly performed Aurelius content through StreamNow's free ad-supported streaming television ("FAST") channels without authorization.

Proposed Forum:

U.S. District Court for the Central District of California, Los Angeles Division. Jurisdiction is anticipated to be based on federal question jurisdiction under 28 U.S.C. § 1331 (copyright claims arising under federal law) and supplemental jurisdiction under 28 U.S.C. § 1367 for the state law unfair competition claims.

Responsible Partner:

Marcus Delgado, Partner, intellectual Property Group, Los Angeles office.

Billing Partner:

Catherine Bloom, Partner, intellectual Property Group, Los Angeles office.

Lead Associate:

Wendy Schultz, Senior Associate, intellectual Property Group, Los Angeles office.

Working Associate:

Omar Siddiqui, Associate, intellectual Property Group, Los Angeles office.

III. Parties and Individuals Searched

The following parties and individuals were run through the Firm's conflicts database, which covers current and former client matters, adverse parties, individual parties (including officers, directors, and key personnel), co-counsel and opposing counsel, affiliated entities, and related third parties across all Calderwood & Harkness offices. Each party was searched using exact name matches as well as phonetic and alias variations, as described more fully in Section IV below.

A. Client-Side Parties

1. Aurelius Global Media Group PLC — Public limited company incorporated in England and Wales, Companies House Registration No. 08724561, with its principal offices at 45 Clarewood Place, London W1K 6TH, United Kingdom. Prospective client in this matter.

2. Aurelius Media Americas, Inc. — Delaware corporation, wholly-owned subsidiary of Aurelius Global Media Group PLC, with its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA holds U.S. copyright registrations for the audiovisual works at issue and will likely be named as a co-plaintiff or real party in interest.

3. Sir Alistair Pemberton — Chief Executive Officer, Aurelius Global Media Group PLC. Sir Alistair has served as CEO since 2019 and may be a witness in connection with Aurelius's licensing practices and corporate structure.

4. Fiona Hartwell — General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell is the Firm's primary client contact and the individual who initiated the engagement discussion.

5. Raj Anantharam — Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC. Mr. Anantharam oversees the licensing relationships that are at the center of the dispute, including the content catalog that StreamNow allegedly exploited without authorization.

6. Lena Kowalski — Head of Digital Rights Enforcement, Aurelius Global Media Group PLC. Ms. Kowalski is responsible for Aurelius's global anti-piracy and digital rights management enforcement program and initially identified the allegedly infringing activity by StreamNow.

B. Adverse / Prospective Defendant Parties

7. StreamNow Holdings, Inc. — Delaware corporation, Delaware Secretary of State File No. 7291843, with its principal place of business at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow is a digital streaming platform operator that distributes content through both subscription-based and free ad-supported streaming television ("FAST") channels. StreamNow is the primary anticipated defendant in the Proposed Engagement.

8. Derek Calloway — Chief Executive Officer and Co-Founder of StreamNow Holdings, Inc. Mr. Calloway co-founded StreamNow in 2018 and serves as its principal executive officer.

9. Priya Menon — Chief Operating Officer and Co-Founder of StreamNow Holdings, Inc. Ms. Menon co-founded StreamNow with Mr. Calloway and oversees the company's day-to-day operations, including content acquisition and technology platform development.

10. Tobias Rennert — General Counsel, StreamNow Holdings, Inc. Mr. Rennert serves as StreamNow's chief legal officer and is expected to be the primary recipient of pre-suit demand correspondence.

11. Sandra Yee — Vice President, Content Acquisition, StreamNow Holdings, Inc. Ms. Yee is believed to have been directly involved in negotiating and executing the content licensing arrangements with MDD through which StreamNow allegedly obtained and distributed the infringing content.

12. Meridian Digital Distributors, LLC — California limited liability company, California Secretary of State File No. 202115729430, with its principal place of business at 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD is a digital content distribution intermediary that purportedly sublicensed Aurelius-owned content to StreamNow without authorization. MDD is an anticipated co-defendant.

13. Franklin Ogilvie — Sole Member and Manager of Meridian Digital Distributors, LLC. Mr. Ogilvie is a former employee of Aurelius Media Americas, Inc., where he served as a licensing manager from approximately 2017 through June 30, 2021. His separation agreement dated June 30, 2021 included non-competition, non-solicitation, and intellectual property use prohibitions. Aurelius's claims against Mr. Ogilvie may include breach of contract (separation agreement) and misappropriation of confidential information, in addition to the core copyright infringement claims. Mr. Ogilvie is an anticipated individual defendant.

C. StreamNow's Investor

14. Pinnacle Ventures Fund III, LP — Delaware limited partnership, with its principal office at 101 California Street, Suite 3500, San Francisco, California 94111. Pinnacle Fund III is the majority owner of StreamNow, holding approximately 62% of StreamNow's fully diluted equity following a $145 million Series C investment closed in June 2022. While Pinnacle Fund III is not currently anticipated as a named defendant, it was searched as a related party due to its significant ownership stake in StreamNow and the possibility that discovery or other aspects of the litigation may affect its interests.

15. Pinnacle Ventures Management III, LLC — General partner of Pinnacle Ventures Fund III, LP. Searched as an affiliated entity of the StreamNow investor.

16. Howard Cheng — Managing Partner, Pinnacle Ventures. Mr. Cheng is the senior investment professional responsible for the Pinnacle Fund III investment in StreamNow and serves on StreamNow's board of directors.

D. StreamNow's Outside Counsel

17. Grantham Roth & Pearce LLP — 555 South Flower Street, Suite 4200, Los Angeles, California 90071. Grantham Roth & Pearce is believed to be StreamNow's primary outside litigation counsel and is expected to represent StreamNow in the anticipated copyright infringement proceedings.

18. Victoria Langford — Partner, intellectual Property Litigation Group, Grantham Roth & Pearce LLP. Ms. Langford is expected to serve as lead counsel for StreamNow.

19. Brian Matsuda — Associate, Grantham Roth & Pearce LLP. Mr. Matsuda is expected to be part of the StreamNow defense team.

E. Third-Party FAST Channel Sublicensees (Potential Additional Adverse Parties)

The following four entities are operators of free ad-supported streaming television ("FAST") channels that received Aurelius-owned content through sublicensing arrangements with StreamNow. These entities may be named as additional defendants or co-conspirators in the litigation, depending on the outcome of the pre-suit investigation:

20. Brindoval Channel Networks, Inc. — Dallas, Texas. FAST channel operator specializing in classic film and television content.

21. BrightLoop Media, LLC — Miami, Florida. FAST channel operator with a focus on independent and international film content.

22. Velvet Stream Partners, LP — Toronto, Ontario, Canada. Canadian-based digital content aggregator and FAST channel operator.

23. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia. Australian-based digital streaming platform and FAST channel operator.

F. Client's Other Advisors and Related Parties (Searched for Completeness)

The following parties are advisors to or contractual counterparties of Aurelius and were searched as a matter of best practice to ensure the absence of any business relationships, joint representations, or other circumstances that could give rise to a conflict or the appearance of a conflict:

24. Bexley Marsh Solicitors LLP — 14 Bedford Row, London WC1R 4ED, United Kingdom. Bexley Marsh serves as Aurelius's UK-based outside intellectual property counsel and has been involved in the preliminary factual investigation of the StreamNow matter. Calderwood & Harkness's engagement would be complementary, serving as U.S. litigation counsel.

25. Whitmore & Pryce LLP — 25 Old Broad Street, London EC2N 1HQ, United Kingdom. Whitmore & Pryce serves as the external auditor for Aurelius Global Media Group PLC.

26. Fortbridge Specialty Insurance Company — 280 Trumbull Street, Hartford, Connecticut 06103. Fortbridge provides media liability and intellectual property enforcement insurance coverage to Aurelius under Policy No. FSI-ML-2024-07821. Depending on the terms of coverage, Fortbridge may have notification and cooperation rights with respect to the Proposed Engagement and any resulting litigation.

27. Calder & Whitfield Insurance Brokers Ltd. — 71 Fenchurch Street, London EC3M 4BS, United Kingdom. Calder & Whitfield serves as Aurelius's insurance broker and placed the Fortbridge media liability policy.

G. Proposed Expert Consultants (To Be Retained by Calderwood & Harkness)

The following expert consultants have been identified as potential retention candidates for the Proposed Engagement and were included in the conflict check to ensure the absence of any relationships with adverse parties that could compromise their independence or create a conflict for the Firm:

28. CipherTrace Analytics, LLC — 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. CipherTrace is a digital forensics firm specializing in content fingerprinting, watermark analysis, and the tracing of unauthorized digital distribution chains. Dr. Nathan Frey would serve as the engagement lead. CipherTrace is anticipated to conduct forensic analysis of StreamNow's content delivery infrastructure and FAST channel distribution to document the scope of the alleged infringement.

29. Lexington IP Services, Inc. — 1625 I Street NW, Suite 400, Washington, DC 20006. Lexington IP Services is a copyright registration search and research firm. Marissa Chung, Director of Copyright Research, would serve as the engagement lead. Lexington is expected to conduct a comprehensive review of all U.S. Copyright Office registrations for the 217 audiovisual works at issue to confirm registration status, chain of title, and the timeliness of registration for statutory damages purposes.

30. Hargrove Economic Consulting Group, LLC — 350 South Grand Avenue, Suite 2800, Los Angeles, California 90071. Hargrove is an economic consulting firm specializing in damages analysis in intellectual property disputes. Dr. Elena Vasquez would serve as the engagement lead. Hargrove has already prepared a preliminary damages estimate of $41.3 million and would be retained to refine and support that analysis through discovery and, if necessary, to provide expert testimony at trial.

H. StreamNow's Registered Agent

31. Capitol Registered Agents, Inc. — 1209 Orange Street, Wilmington, Delaware 19801. Capitol Registered Agents serves as the registered agent for service of process for StreamNow Holdings, Inc. in the State of Delaware. This entity was searched for completeness, although no substantive relationship with the Firm is anticipated.

IV. Conflict Check Methodology

The conflict check was conducted using Calderwood & Harkness's firm-wide electronic conflicts database (the "System"), which is maintained by the Firm's Office of the General Counsel in coordination with the Information Technology Department. The System captures and indexes all current and former client matters, adverse parties, individual parties (including officers, directors, key employees, and other relevant personnel), co-counsel and opposing counsel, affiliated entities, and related third parties across all Calderwood & Harkness offices, including the Firm's offices in New York, Los Angeles, San Francisco, Washington, D.C., London, and Hong Kong.

All thirty-one (31) names identified in Section III above were searched using both exact name matches and phonetic/alias variations. The phonetic search function employs the Soundex and Double Metaphone algorithms to capture alternate spellings, transliterations, and common variations. In addition, corporate entity names were searched with and without common suffixes (e.g., "Inc.," "LLC," "LP," "PLC," "Ltd.," "Pty Ltd") and with abbreviated and unabbreviated forms of key terms (e.g., "StreamNow" and "Stream Now"). Individual names were searched using first name, last name, and any known middle names or initials, as well as common nickname variations.

The System's database covers all matters opened or active within at least the preceding ten (10) years from the date of each search, which encompasses the full period during which the factual circumstances underlying the Aurelius-StreamNow dispute developed. Archived matter records predating the ten-year window are accessible through a supplemental archive query, which was also run for all parties.

The conflict check was conducted in three phases:

Phase 1 — January 16, 2026: Initial search conducted by Wendy Schultz. This phase covered parties 1 through 13 (client-side parties, primary adverse/prospective defendant parties, and Franklin Ogilvie) as identified during the initial consultation with Ms. Hartwell on January 15, 2026.

Phase 2 — January 30, 2026: Supplemental search conducted by Wendy Schultz. This phase added parties 14 through 27 (StreamNow's investor and its affiliated entities, StreamNow's anticipated outside counsel, the four FAST channel sublicensees, the client's other advisors and related parties, and StreamNow's registered agent). These parties were identified through additional due diligence conducted between January 17 and January 29, 2026, including review of StreamNow's corporate filings, publicly available investor information, and communications with Ms. Hartwell regarding Aurelius's advisory relationships.

Phase 3 — February 7, 2026: Supplemental search conducted by Wendy Schultz. This phase added parties 28 through 31 (proposed expert consultants and StreamNow's registered agent). These parties were finalized as potential engagement candidates following internal discussions among the proposed matter team.

All search results were compiled, reviewed, and analyzed by Wendy Schultz in accordance with Firm Policy No. 2019-COI-003. The compiled results were submitted to Marcus Delgado for final review on February 8, 2026. Mr. Delgado reviewed and approved the results on February 10, 2026.

V. Results of Conflict Check

A. Current Client Relationships

Aurelius Global Media Group PLC / Aurelius Media Americas, Inc.: No prior or existing attorney-client relationship was found in the Firm's database for either Aurelius Global Media Group PLC or its U.S. subsidiary, Aurelius Media Americas, Inc. The System returned no matches — exact or approximate — for either entity name. This will be a new client engagement for Calderwood & Harkness LLP.

No representation of any Aurelius officer, director, or employee was identified in the Firm's database, including Sir Alistair Pemberton (CEO), Fiona Hartwell (General Counsel), Raj Anantharam (SVP, Content Licensing & Distribution), and Lena Kowalski (Head of Digital Rights Enforcement). None of these individuals has been a client, adverse party, or related party in any matter handled by the Firm.

B. Adverse Parties — StreamNow Holdings, Inc.

StreamNow Holdings, Inc.: No current or former representation of StreamNow Holdings, Inc. was identified in the System. Calderwood & Harkness has not previously acted for or against StreamNow in any matter, whether in an advisory, transactional, or litigation capacity. The System returned no matches — exact or approximate — for "StreamNow Holdings, Inc.," "StreamNow Holdings," "StreamNow," or "Stream Now."

Derek Calloway (CEO & Co-Founder, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Mr. Calloway was found.

Priya Menon (COO & Co-Founder, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Ms. Menon was found.

Tobias Rennert (General Counsel, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Mr. Rennert was found.

Sandra Yee (VP, Content Acquisition, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Ms. Yee was found.

C. Adverse Parties — Meridian Digital Distributors, LLC / Franklin Ogilvie

Meridian Digital Distributors, LLC: No current or former representation of MDD was identified in the System. The Firm has not acted for or against MDD in any matter. The System returned no matches for "Meridian Digital Distributors, LLC," "Meridian Digital Distributors," or "Meridian Digital."

Franklin Ogilvie: No current or former representation of Mr. Ogilvie was identified in the System. No prior relationship of any kind between the Firm and Mr. Ogilvie was found. It is noted, for purposes of this memorandum, that Mr. Ogilvie is a former employee of Aurelius Media Americas, Inc., having served as a licensing manager from approximately 2017 through June 30, 2021. According to information provided by Ms. Hartwell, Mr. Ogilvie's separation agreement dated June 30, 2021 included covenants relating to non-competition, non-solicitation, and prohibitions on the use of Aurelius's intellectual property and confidential information. Aurelius alleges that Mr. Ogilvie, through MDD, facilitated the sublicensing of Aurelius-owned content to StreamNow in breach of these obligations. Although Mr. Ogilvie's former employment relationship with the prospective client is relevant to the underlying merits of the dispute, it does not give rise to any conflict-of-interest issue for the Firm, as Calderwood & Harkness has never represented Mr. Ogilvie in any capacity.

D. StreamNow Investor — Pinnacle Ventures

Pinnacle Ventures Fund III, LP: No current or former representation of Pinnacle Ventures Fund III, LP was identified in the System. The Firm has not acted for or against this entity in any capacity.

Pinnacle Ventures Management III, LLC: No current or former representation of Pinnacle Ventures Management III, LLC was identified in the System. The Firm has not acted for or against this entity in any capacity.

Howard Cheng (Managing Partner, Pinnacle Ventures): No current or former representation of Mr. Cheng was identified in the System. No prior relationship of any kind between the Firm and Mr. Cheng was found.

The search for Pinnacle Ventures-related entities included variations of the "Pinnacle Ventures" name (including "Pinnacle Ventures," "Pinnacle Fund," "Pinnacle Capital," "Pinnacle Partners," and "Pinnacle Management") and was cross-checked against the Firm's fund/investment client index, which catalogs all venture capital, private equity, and investment fund clients and counterparties. No hits were returned from any of these searches.

E. StreamNow's Outside Counsel — Grantham Roth & Pearce LLP

Grantham Roth & Pearce LLP: No current or former co-counsel or opposing counsel relationship was identified in the System that would create a conflict or give rise to any concern. While Grantham Roth & Pearce is a well-established litigation firm in the Los Angeles legal market and its attorneys may have appeared in matters involving Calderwood & Harkness attorneys in the ordinary course, no specific matter was identified in which the two firms served as co-counsel, opposing counsel, or otherwise had a relationship that would implicate any conflict-of-interest rule or create an appearance of impropriety.

Victoria Langford (Partner, IP Litigation, Grantham Roth & Pearce): No prior opposing counsel or co-counsel relationship with any Calderwood & Harkness attorney was identified.

Brian Matsuda (Associate, Grantham Roth & Pearce): No prior opposing counsel or co-counsel relationship with any Calderwood & Harkness attorney was identified.

F. FAST Channel Sublicensees

Brindoval Channel Networks, Inc. (Dallas, Texas): No current or former representation identified in the System. The Firm has not acted for or against this entity.

BrightLoop Media, LLC (Miami, Florida): No current or former representation identified in the System. The Firm has not acted for or against this entity.

Velvet Stream Partners, LP (Toronto, Ontario, Canada): No current or former representation identified in the System. The Firm has not acted for or against this entity.

Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia): No current or former representation identified in the System. The Firm has not acted for or against this entity.

G. Client's Other Advisors and Related Third Parties

Bexley Marsh Solicitors LLP: No current or former relationship was identified in the System that would create a conflict. Bexley Marsh is serving as Aurelius's UK outside intellectual property counsel in connection with the same underlying dispute. Calderwood & Harkness's proposed engagement is complementary — the Firm would serve as U.S. litigation counsel — and no conflict arises from the concurrent representation of the same client by two separate law firms in different jurisdictions. No adverse relationship with Bexley Marsh was identified.

Whitmore & Pryce LLP: No current or former relationship identified in the System. Whitmore & Pryce's role as Aurelius's external auditor does not give rise to any conflict for the Firm.

Fortbridge Specialty Insurance Company: No current or former representation of Fortbridge Specialty Insurance Company was identified in the System. The Firm has not acted for or against Fortbridge. As Aurelius's media liability and intellectual property enforcement insurer under Policy No. FSI-ML-2024-07821, Fortbridge may be notified of the proposed litigation and may have certain rights under the policy, but no adversity between Calderwood & Harkness and Fortbridge is anticipated. If coverage issues arise during the course of the engagement, the analysis will be revisited at that time.

Calder & Whitfield Insurance Brokers Ltd.: No current or former representation identified in the System. No relationship of any kind between the Firm and Calder & Whitfield was found.

Capitol Registered Agents, Inc.: No current or former representation identified in the System. Capitol Registered Agents serves only as the statutory registered agent for service of process for StreamNow Holdings, Inc. in the State of Delaware and has no substantive involvement in the underlying dispute.

H. Proposed Expert Consultants

CipherTrace Analytics, LLC / Dr. Nathan Frey: No conflicts identified. The System returned no matches for CipherTrace Analytics, LLC or for Dr. Nathan Frey. CipherTrace has not been retained by any adverse party in this matter or in any related matter within the Firm's records. Dr. Frey has not appeared as an expert, consultant, or party in any matter adverse to a Calderwood & Harkness client.

Lexington IP Services, Inc. / Marissa Chung: No conflicts identified. The System returned no matches for Lexington IP Services, Inc. or for Marissa Chung. No prior engagement of Lexington by any adverse party was found.

Hargrove Economic Consulting Group, LLC / Dr. Elena Vasquez: No conflicts identified. The System returned no matches for Hargrove Economic Consulting Group, LLC or for Dr. Elena Vasquez. No prior engagement of Hargrove by any adverse party was found. It is noted that Hargrove has already performed preliminary damages analysis for Aurelius in connection with this matter and has produced the $41.3 million preliminary damages estimate referenced in Section II above, which does not create any conflict for the Firm.

VI. Analysis of Potential Issues

In addition to the database search results set forth in Section V, the following analysis addresses specific categories of potential conflicts and ethical issues that were considered in connection with the Proposed Engagement.

A. No Duty of Loyalty Conflicts

Calderwood & Harkness owes no existing duty of loyalty to StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Pinnacle Ventures Fund III, LP, Pinnacle Ventures Management III, LLC, any of the four FAST channel sublicensees (Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd), or any individual officer, director, employee, or agent associated with any of those entities. None of these parties is a current client of the Firm. Accordingly, the Firm's representation of Aurelius against these parties does not implicate California Rule of Professional Conduct 1.7(a) (prohibiting representation directly adverse to a current client) or 1.7(b) (prohibiting representation where there is a significant risk that the representation will be materially limited by the lawyer's responsibilities to another client, a former client, or a third person, or by a personal interest of the lawyer).

B. No Business Transaction / Personal Interest Conflicts

No partner, counsel, or associate at the Firm has disclosed any financial interest in StreamNow Holdings, Inc., Pinnacle Ventures Fund III, LP, Pinnacle Ventures Management III, LLC, Meridian Digital Distributors, LLC, or any entity related to any of the prospective adverse parties. A supplemental inquiry was made of all partners in the Firm's Los Angeles and San Francisco offices, consistent with Firm Policy No. 2019-COI-003, Section 4.3 (requiring affirmative disclosure of personal financial interests in adverse parties). All responses were negative. No partner holds investments in Pinnacle Ventures Fund III, LP or any other Pinnacle Ventures-managed fund. Accordingly, no personal interest conflict under California Rule of Professional Conduct 1.7(b) exists.

C. No Former Client Conflicts

The Firm has no former client relationships that would be substantially related to the subject matter of the Aurelius-StreamNow copyright infringement dispute. The System search confirmed that neither StreamNow nor any of the other adverse parties has ever been a client of the Firm. No former client matter was identified in which the confidential information obtained during the prior representation could be used to the disadvantage of a former client in this engagement. Accordingly, no conflict under California Rule of Professional Conduct 1.9 (Duties to Former Clients) exists. Similarly, no lawyer at the Firm has previously represented any of the adverse parties or their affiliates in a matter substantially related to this engagement while employed at a prior firm, and no imputation issue under California Rule of Professional Conduct 1.10 has been identified.

D. No Co-Counsel / Former Opposing Counsel Issues

Grantham Roth & Pearce LLP, which is anticipated to serve as StreamNow's outside litigation counsel in the Proposed Engagement, has not served as co-counsel with, or opposing counsel to, Calderwood & Harkness in any matter that would give rise to a conflict of interest or create an appearance of impropriety. While individual attorneys at both firms may have participated in matters involving the other firm in the ordinary course of practice in the Los Angeles legal market, no specific matter was identified that would implicate any ethical rule or create any concern regarding the Firm's ability to represent Aurelius zealously and without divided loyalty.

E. New Client Intake

Aurelius Global Media Group PLC is a new client for Calderwood & Harkness LLP. The Firm has not previously represented Aurelius or any of its subsidiaries, affiliates, officers, or directors. Standard new client intake procedures must be completed before the engagement is formally opened. Given that Aurelius is a public limited company incorporated in England and Wales, the intake procedures will include Know Your Customer ("KYC") and Anti-Money Laundering ("AML") due diligence requirements applicable to UK-incorporated entities, consistent with Firm Policy No. 2021-KYC-001 (Client Identification and Verification for International Clients). Verification of the authority of Fiona Hartwell to engage Calderwood & Harkness on behalf of Aurelius and its subsidiaries will also be completed as part of the engagement letter process. It is anticipated that the KYC/AML review and authority verification will be conducted concurrently with the finalization and execution of the engagement letter.

VII. Conclusion and Clearance

Based on the comprehensive results of the conflict-of-interest check conducted across all Calderwood & Harkness offices and databases, as documented in this memorandum, no conflicts of interest have been identified that would preclude Calderwood & Harkness LLP from representing Aurelius Global Media Group PLC and its wholly-owned subsidiary, Aurelius Media Americas, Inc., in connection with the pre-suit copyright infringement assessment, demand, and potential litigation against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and related parties, as described herein (Matter No. 1017-00003).

The engagement is cleared to proceed.

The following steps should be taken to formalize the engagement:

1. The engagement letter should be finalized in accordance with the Firm's standard form for new client litigation engagements, incorporating any client-specific terms discussed during the initial consultation with Ms. Hartwell, and transmitted to Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC, for review and execution.

2. It is recommended that the matter be formally opened in the Firm's matter management system upon receipt of the fully executed engagement letter and the initial retainer deposit of $150,000, as discussed with Ms. Hartwell during the January 15, 2026 consultation.

3. New client intake procedures, including KYC/AML due diligence for Aurelius as a UK-incorporated public limited company and verification of Ms. Hartwell's authority to engage the Firm, should be completed concurrently with the engagement letter process.

4. Upon formal opening of the matter, a supplemental conflict check should be conducted if and when additional parties, witnesses, or related entities are identified during the course of the pre-suit investigation and any subsequent litigation.

VIII. Approval

Prepared by:

________________________________________

Wendy Schultz Senior Associate, intellectual Property Calderwood & Harkness LLP — Los Angeles Office

Date: February 10, 2026

Reviewed and Approved by:

________________________________________

Marcus Delgado Partner, intellectual Property Calderwood & Harkness LLP — Los Angeles Office

Date: February 10, 2026

Engagement Cleared: Yes

APPENDIX A

Summary Table of Parties Searched and Results

The following table sets forth all thirty-one (31) parties and individuals searched in connection with the conflict check for Matter No. 1017-00003, together with the entity type, role in the matter, date of initial search, and result.

End of Memorandum — Matter No. 1017-00003 Calderwood & Harkness LLP — Privileged & Confidential — Attorney Work Product

FROM:	Wendy Schultz, Senior Associate, intellectual Property
TO:	Marcus Delgado, Partner, intellectual Property
CC:	Catherine Bloom, Partner, intellectual Property
DATE:	February 10, 2026
RE:	Conflict of Interest Check — Proposed Representation of Aurelius Global Media Group PLC — Matter No. 1017-00003
No.	Party / Individual	Entity Type	Role in Matter	Date Searched	Result
1	Aurelius Global Media Group PLC	Public limited company (England & Wales)	Client	Jan. 16, 2026	No Conflict
2	Aurelius Media Americas, Inc.	Delaware corporation	Client (subsidiary)	Jan. 16, 2026	No Conflict
3	Sir Alistair Pemberton	Individual	Client officer (CEO)	Jan. 16, 2026	No Conflict
4	Fiona Hartwell	Individual	Client officer (GC)	Jan. 16, 2026	No Conflict
5	Raj Anantharam	Individual	Client officer (SVP)	Jan. 16, 2026	No Conflict
6	Lena Kowalski	Individual	Client officer (Head of DRE)	Jan. 16, 2026	No Conflict
7	StreamNow Holdings, Inc.	Delaware corporation	Adverse / Prospective Defendant	Jan. 16, 2026	No Conflict
8	Derek Calloway	Individual	Adverse (CEO, StreamNow)	Jan. 16, 2026	No Conflict
9	Priya Menon	Individual	Adverse (COO, StreamNow)	Jan. 16, 2026	No Conflict
10	Tobias Rennert	Individual	Adverse (GC, StreamNow)	Jan. 16, 2026	No Conflict
11	Sandra Yee	Individual	Adverse (VP, StreamNow)	Jan. 16, 2026	No Conflict
12	Meridian Digital Distributors, LLC	California LLC	Adverse / Prospective Defendant	Jan. 16, 2026	No Conflict
13	Franklin Ogilvie	Individual	Adverse (Member/Mgr., MDD)	Jan. 16, 2026	No Conflict
14	Pinnacle Ventures Fund III, LP	Delaware LP	Related (StreamNow investor)	Jan. 30, 2026	No Conflict
15	Pinnacle Ventures Management III, LLC	Delaware LLC	Related (GP of Fund III)	Jan. 30, 2026	No Conflict
16	Howard Cheng	Individual	Related (MP, Pinnacle)	Jan. 30, 2026	No Conflict
17	Grantham Roth & Pearce LLP	Law firm (CA)	Opposing counsel	Jan. 30, 2026	No Conflict
18	Victoria Langford	Individual	Opposing counsel (Partner)	Jan. 30, 2026	No Conflict
19	Brian Matsuda	Individual	Opposing counsel (Associate)	Jan. 30, 2026	No Conflict

20	Brindoval Channel Networks, Inc.	Corporation (TX)	Potential additional adverse	Jan. 30, 2026	No Conflict
21	BrightLoop Media, LLC	LLC (FL)	Potential additional adverse	Jan. 30, 2026	No Conflict
22	Velvet Stream Partners, LP	LP (ON, Canada)	Potential additional adverse	Jan. 30, 2026	No Conflict
23	Pacific Lantern Digital Pty Ltd	Pty Ltd (NSW, Australia)	Potential additional adverse	Jan. 30, 2026	No Conflict
24	Bexley Marsh Solicitors LLP	Law firm (UK)	Client's UK IP counsel	Jan. 30, 2026	No Conflict
25	Whitmore & Pryce LLP	Accounting firm (UK)	Client's auditor	Jan. 30, 2026	No Conflict
26	Fortbridge Specialty Insurance Co.	Insurance company (CT)	Client's insurer	Jan. 30, 2026	No Conflict
27	Calder & Whitfield Insurance Brokers Ltd.	Insurance broker (UK)	Client's broker	Jan. 30, 2026	No Conflict
28	CipherTrace Analytics, LLC	LLC (CA)	Proposed expert (forensics)	Feb. 7, 2026	No Conflict
29	Lexington IP Services, Inc.	Corporation (DC)	Proposed expert (copyright)	Feb. 7, 2026	No Conflict
30	Hargrove Economic Consulting Group, LLC	LLC (CA)	Proposed expert (damages)	Feb. 7, 2026	No Conflict
31	Capitol Registered Agents, Inc.	Corporation (DE)	Related (registered agent)	Feb. 7, 2026	No Conflict

MEMORANDUM — PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT
CALDERWOOD & HARKNESS LLP
Los Angeles Office 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
This memorandum is protected by the attorney-client privilege and constitutes attorney work product. It is intended solely for the use of the named recipients. Any dissemination, distribution, or copying of this memorandum or any portion thereof is strictly prohibited without the prior written consent of the General Counsel's Office of Calderwood & Harkness LLP.
I. Purpose
This memorandum documents the results of the firm's conflict-of-interest check conducted in connection with the proposed engagement of Calderwood & Harkness LLP ("C&H" or the "Firm") by Aurelius Global Media Group PLC ("Aurelius" or "AGMG") for pre-suit copyright infringement assessment and enforcement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and related parties (collectively, the "Proposed Engagement").
The conflict check was initiated on January 16, 2026, following Marcus Delgado's initial consultation with Fiona Hartwell, General Counsel of Aurelius, which took place on January 15, 2026, at the Firm's Los Angeles office. During that consultation, Ms. Hartwell provided preliminary information regarding the identities of the parties likely to be involved in the matter, the nature of the anticipated claims, and the scope of legal services Aurelius seeks to retain C&H to perform. Supplemental searches were subsequently conducted on January 30, 2026 and February 7, 2026 to account for additional parties identified during the course of the intake process, including potential additional adverse parties, StreamNow's outside counsel, StreamNow's investor, and proposed expert consultants.
All results were reviewed and finalized as of the date of this memorandum, February 10, 2026. In accordance with Calderwood & Harkness's Conflicts of Interest Policy (Firm Policy No. 2019-COI-003, as amended October 1, 2024) and applicable rules of professional conduct — including, without limitation, the California Rules of Professional Conduct, Rules 1.7 (Conflict of Interest: Current Clients) and 1.9 (Duties to Former Clients) — clearance of this conflict check is required before the engagement can be formally opened and an engagement letter transmitted to the prospective client.
II. Proposed Engagement Summary
The following summarizes the key details of the Proposed Engagement:
Client:
Aurelius Global Media Group PLC, a public limited company incorporated in England and Wales under the Companies Act 2006, Companies House Registration No. 08724561, with its principal offices located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius's American Depositary Receipts ("ADRs") are traded over-the-counter ("OTC") in the United States. Aurelius's ordinary shares are listed on the London Stock Exchange's Alternative Investment Market under the ticker symbol AIM: AGLM. Aurelius is a diversified global media conglomerate with operations spanning film and television production, music publishing, digital content distribution, and live entertainment across Europe, the Americas, and the Asia-Pacific region.
U.S. Subsidiary:
Aurelius Media Americas, Inc. ("AMA"), a wholly-owned Delaware subsidiary of Aurelius Global Media Group PLC, with its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as the primary U.S. operating entity for Aurelius's content licensing and distribution activities in North America and manages the copyright registrations at issue in this matter through the U.S. Copyright Office.
Client Contact:
Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell has been designated by the client as the primary point of contact for all matters related to this engagement and has represented that she possesses the authority to retain outside counsel on behalf of Aurelius and its subsidiaries for purposes of this matter.
Nature of Matter:
Pre-suit assessment, demand, and potential litigation for copyright infringement under 17 U.S.C. §§ 106 and 501 (exclusive rights of copyright owners and infringement of copyright, respectively), together with supplemental state law claims under the California Unfair Competition Law, Cal. Bus. & Prof. Code § 17200 et seq. The claims arise from StreamNow's alleged unauthorized reproduction, distribution, and public performance of 217 Aurelius-owned audiovisual works — including feature-length films, episodic television series, and short-form documentary content — over an approximately 22-month period spanning from on or about April 1, 2024 through January 31, 2026. Preliminary damages have been estimated at $41.3 million by Hargrove Economic Consulting Group, LLC, based on a combination of actual damages and profits attributable to the infringement, with an alternative statutory damages analysis reserved. The matter may also involve secondary liability theories directed at MDD and its principal, Franklin Ogilvie, as well as potential claims against downstream sublicensees who received and publicly performed Aurelius content through StreamNow's free ad-supported streaming television ("FAST") channels without authorization.
Proposed Forum:
U.S. District Court for the Central District of California, Los Angeles Division. Jurisdiction is anticipated to be based on federal question jurisdiction under 28 U.S.C. § 1331 (copyright claims arising under federal law) and supplemental jurisdiction under 28 U.S.C. § 1367 for the state law unfair competition claims.
Responsible Partner:
Marcus Delgado, Partner, intellectual Property Group, Los Angeles office.
Billing Partner:
Catherine Bloom, Partner, intellectual Property Group, Los Angeles office.
Lead Associate:
Wendy Schultz, Senior Associate, intellectual Property Group, Los Angeles office.
Working Associate:
Omar Siddiqui, Associate, intellectual Property Group, Los Angeles office.
III. Parties and Individuals Searched
The following parties and individuals were run through the Firm's conflicts database, which covers current and former client matters, adverse parties, individual parties (including officers, directors, and key personnel), co-counsel and opposing counsel, affiliated entities, and related third parties across all Calderwood & Harkness offices. Each party was searched using exact name matches as well as phonetic and alias variations, as described more fully in Section IV below.
A. Client-Side Parties
1.  Aurelius Global Media Group PLC — Public limited company incorporated in England and Wales, Companies House Registration No. 08724561, with its principal offices at 45 Clarewood Place, London W1K 6TH, United Kingdom. Prospective client in this matter.
2.  Aurelius Media Americas, Inc. — Delaware corporation, wholly-owned subsidiary of Aurelius Global Media Group PLC, with its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA holds U.S. copyright registrations for the audiovisual works at issue and will likely be named as a co-plaintiff or real party in interest.
3.  Sir Alistair Pemberton — Chief Executive Officer, Aurelius Global Media Group PLC. Sir Alistair has served as CEO since 2019 and may be a witness in connection with Aurelius's licensing practices and corporate structure.
4.  Fiona Hartwell — General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell is the Firm's primary client contact and the individual who initiated the engagement discussion.
5.  Raj Anantharam — Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC. Mr. Anantharam oversees the licensing relationships that are at the center of the dispute, including the content catalog that StreamNow allegedly exploited without authorization.
6.  Lena Kowalski — Head of Digital Rights Enforcement, Aurelius Global Media Group PLC. Ms. Kowalski is responsible for Aurelius's global anti-piracy and digital rights management enforcement program and initially identified the allegedly infringing activity by StreamNow.
B. Adverse / Prospective Defendant Parties
7.  StreamNow Holdings, Inc. — Delaware corporation, Delaware Secretary of State File No. 7291843, with its principal place of business at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow is a digital streaming platform operator that distributes content through both subscription-based and free ad-supported streaming television ("FAST") channels. StreamNow is the primary anticipated defendant in the Proposed Engagement.
8.  Derek Calloway — Chief Executive Officer and Co-Founder of StreamNow Holdings, Inc. Mr. Calloway co-founded StreamNow in 2018 and serves as its principal executive officer.
9.  Priya Menon — Chief Operating Officer and Co-Founder of StreamNow Holdings, Inc. Ms. Menon co-founded StreamNow with Mr. Calloway and oversees the company's day-to-day operations, including content acquisition and technology platform development.
10.  Tobias Rennert — General Counsel, StreamNow Holdings, Inc. Mr. Rennert serves as StreamNow's chief legal officer and is expected to be the primary recipient of pre-suit demand correspondence.
11.  Sandra Yee — Vice President, Content Acquisition, StreamNow Holdings, Inc. Ms. Yee is believed to have been directly involved in negotiating and executing the content licensing arrangements with MDD through which StreamNow allegedly obtained and distributed the infringing content.
12.  Meridian Digital Distributors, LLC — California limited liability company, California Secretary of State File No. 202115729430, with its principal place of business at 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD is a digital content distribution intermediary that purportedly sublicensed Aurelius-owned content to StreamNow without authorization. MDD is an anticipated co-defendant.
13.  Franklin Ogilvie — Sole Member and Manager of Meridian Digital Distributors, LLC. Mr. Ogilvie is a former employee of Aurelius Media Americas, Inc., where he served as a licensing manager from approximately 2017 through June 30, 2021. His separation agreement dated June 30, 2021 included non-competition, non-solicitation, and intellectual property use prohibitions. Aurelius's claims against Mr. Ogilvie may include breach of contract (separation agreement) and misappropriation of confidential information, in addition to the core copyright infringement claims. Mr. Ogilvie is an anticipated individual defendant.
C. StreamNow's Investor
14.  Pinnacle Ventures Fund III, LP — Delaware limited partnership, with its principal office at 101 California Street, Suite 3500, San Francisco, California 94111. Pinnacle Fund III is the majority owner of StreamNow, holding approximately 62% of StreamNow's fully diluted equity following a $145 million Series C investment closed in June 2022. While Pinnacle Fund III is not currently anticipated as a named defendant, it was searched as a related party due to its significant ownership stake in StreamNow and the possibility that discovery or other aspects of the litigation may affect its interests.
15.  Pinnacle Ventures Management III, LLC — General partner of Pinnacle Ventures Fund III, LP. Searched as an affiliated entity of the StreamNow investor.
16.  Howard Cheng — Managing Partner, Pinnacle Ventures. Mr. Cheng is the senior investment professional responsible for the Pinnacle Fund III investment in StreamNow and serves on StreamNow's board of directors.
D. StreamNow's Outside Counsel
17.  Grantham Roth & Pearce LLP — 555 South Flower Street, Suite 4200, Los Angeles, California 90071. Grantham Roth & Pearce is believed to be StreamNow's primary outside litigation counsel and is expected to represent StreamNow in the anticipated copyright infringement proceedings.
18.  Victoria Langford — Partner, intellectual Property Litigation Group, Grantham Roth & Pearce LLP. Ms. Langford is expected to serve as lead counsel for StreamNow.
19.  Brian Matsuda — Associate, Grantham Roth & Pearce LLP. Mr. Matsuda is expected to be part of the StreamNow defense team.
E. Third-Party FAST Channel Sublicensees (Potential Additional Adverse Parties)
The following four entities are operators of free ad-supported streaming television ("FAST") channels that received Aurelius-owned content through sublicensing arrangements with StreamNow. These entities may be named as additional defendants or co-conspirators in the litigation, depending on the outcome of the pre-suit investigation:
20.  Brindoval Channel Networks, Inc. — Dallas, Texas. FAST channel operator specializing in classic film and television content.
21.  BrightLoop Media, LLC — Miami, Florida. FAST channel operator with a focus on independent and international film content.
22.  Velvet Stream Partners, LP — Toronto, Ontario, Canada. Canadian-based digital content aggregator and FAST channel operator.
23.  Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia. Australian-based digital streaming platform and FAST channel operator.
F. Client's Other Advisors and Related Parties (Searched for Completeness)
The following parties are advisors to or contractual counterparties of Aurelius and were searched as a matter of best practice to ensure the absence of any business relationships, joint representations, or other circumstances that could give rise to a conflict or the appearance of a conflict:
24.  Bexley Marsh Solicitors LLP — 14 Bedford Row, London WC1R 4ED, United Kingdom. Bexley Marsh serves as Aurelius's UK-based outside intellectual property counsel and has been involved in the preliminary factual investigation of the StreamNow matter. Calderwood & Harkness's engagement would be complementary, serving as U.S. litigation counsel.
25.  Whitmore & Pryce LLP — 25 Old Broad Street, London EC2N 1HQ, United Kingdom. Whitmore & Pryce serves as the external auditor for Aurelius Global Media Group PLC.
26.  Fortbridge Specialty Insurance Company — 280 Trumbull Street, Hartford, Connecticut 06103. Fortbridge provides media liability and intellectual property enforcement insurance coverage to Aurelius under Policy No. FSI-ML-2024-07821. Depending on the terms of coverage, Fortbridge may have notification and cooperation rights with respect to the Proposed Engagement and any resulting litigation.
27.  Calder & Whitfield Insurance Brokers Ltd. — 71 Fenchurch Street, London EC3M 4BS, United Kingdom. Calder & Whitfield serves as Aurelius's insurance broker and placed the Fortbridge media liability policy.
G. Proposed Expert Consultants (To Be Retained by Calderwood & Harkness)
The following expert consultants have been identified as potential retention candidates for the Proposed Engagement and were included in the conflict check to ensure the absence of any relationships with adverse parties that could compromise their independence or create a conflict for the Firm:
28.  CipherTrace Analytics, LLC — 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. CipherTrace is a digital forensics firm specializing in content fingerprinting, watermark analysis, and the tracing of unauthorized digital distribution chains. Dr. Nathan Frey would serve as the engagement lead. CipherTrace is anticipated to conduct forensic analysis of StreamNow's content delivery infrastructure and FAST channel distribution to document the scope of the alleged infringement.
29.  Lexington IP Services, Inc. — 1625 I Street NW, Suite 400, Washington, DC 20006. Lexington IP Services is a copyright registration search and research firm. Marissa Chung, Director of Copyright Research, would serve as the engagement lead. Lexington is expected to conduct a comprehensive review of all U.S. Copyright Office registrations for the 217 audiovisual works at issue to confirm registration status, chain of title, and the timeliness of registration for statutory damages purposes.
30.  Hargrove Economic Consulting Group, LLC — 350 South Grand Avenue, Suite 2800, Los Angeles, California 90071. Hargrove is an economic consulting firm specializing in damages analysis in intellectual property disputes. Dr. Elena Vasquez would serve as the engagement lead. Hargrove has already prepared a preliminary damages estimate of $41.3 million and would be retained to refine and support that analysis through discovery and, if necessary, to provide expert testimony at trial.
H. StreamNow's Registered Agent
31.  Capitol Registered Agents, Inc. — 1209 Orange Street, Wilmington, Delaware 19801. Capitol Registered Agents serves as the registered agent for service of process for StreamNow Holdings, Inc. in the State of Delaware. This entity was searched for completeness, although no substantive relationship with the Firm is anticipated.
IV. Conflict Check Methodology
The conflict check was conducted using Calderwood & Harkness's firm-wide electronic conflicts database (the "System"), which is maintained by the Firm's Office of the General Counsel in coordination with the Information Technology Department. The System captures and indexes all current and former client matters, adverse parties, individual parties (including officers, directors, key employees, and other relevant personnel), co-counsel and opposing counsel, affiliated entities, and related third parties across all Calderwood & Harkness offices, including the Firm's offices in New York, Los Angeles, San Francisco, Washington, D.C., London, and Hong Kong.
All thirty-one (31) names identified in Section III above were searched using both exact name matches and phonetic/alias variations. The phonetic search function employs the Soundex and Double Metaphone algorithms to capture alternate spellings, transliterations, and common variations. In addition, corporate entity names were searched with and without common suffixes (e.g., "Inc.," "LLC," "LP," "PLC," "Ltd.," "Pty Ltd") and with abbreviated and unabbreviated forms of key terms (e.g., "StreamNow" and "Stream Now"). Individual names were searched using first name, last name, and any known middle names or initials, as well as common nickname variations.
The System's database covers all matters opened or active within at least the preceding ten (10) years from the date of each search, which encompasses the full period during which the factual circumstances underlying the Aurelius-StreamNow dispute developed. Archived matter records predating the ten-year window are accessible through a supplemental archive query, which was also run for all parties.
The conflict check was conducted in three phases:
Phase 1 — January 16, 2026: Initial search conducted by Wendy Schultz. This phase covered parties 1 through 13 (client-side parties, primary adverse/prospective defendant parties, and Franklin Ogilvie) as identified during the initial consultation with Ms. Hartwell on January 15, 2026.
Phase 2 — January 30, 2026: Supplemental search conducted by Wendy Schultz. This phase added parties 14 through 27 (StreamNow's investor and its affiliated entities, StreamNow's anticipated outside counsel, the four FAST channel sublicensees, the client's other advisors and related parties, and StreamNow's registered agent). These parties were identified through additional due diligence conducted between January 17 and January 29, 2026, including review of StreamNow's corporate filings, publicly available investor information, and communications with Ms. Hartwell regarding Aurelius's advisory relationships.
Phase 3 — February 7, 2026: Supplemental search conducted by Wendy Schultz. This phase added parties 28 through 31 (proposed expert consultants and StreamNow's registered agent). These parties were finalized as potential engagement candidates following internal discussions among the proposed matter team.
All search results were compiled, reviewed, and analyzed by Wendy Schultz in accordance with Firm Policy No. 2019-COI-003. The compiled results were submitted to Marcus Delgado for final review on February 8, 2026. Mr. Delgado reviewed and approved the results on February 10, 2026.
V. Results of Conflict Check
A. Current Client Relationships
Aurelius Global Media Group PLC / Aurelius Media Americas, Inc.: No prior or existing attorney-client relationship was found in the Firm's database for either Aurelius Global Media Group PLC or its U.S. subsidiary, Aurelius Media Americas, Inc. The System returned no matches — exact or approximate — for either entity name. This will be a new client engagement for Calderwood & Harkness LLP.
No representation of any Aurelius officer, director, or employee was identified in the Firm's database, including Sir Alistair Pemberton (CEO), Fiona Hartwell (General Counsel), Raj Anantharam (SVP, Content Licensing & Distribution), and Lena Kowalski (Head of Digital Rights Enforcement). None of these individuals has been a client, adverse party, or related party in any matter handled by the Firm.
B. Adverse Parties — StreamNow Holdings, Inc.
StreamNow Holdings, Inc.: No current or former representation of StreamNow Holdings, Inc. was identified in the System. Calderwood & Harkness has not previously acted for or against StreamNow in any matter, whether in an advisory, transactional, or litigation capacity. The System returned no matches — exact or approximate — for "StreamNow Holdings, Inc.," "StreamNow Holdings," "StreamNow," or "Stream Now."
Derek Calloway (CEO & Co-Founder, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Mr. Calloway was found.
Priya Menon (COO & Co-Founder, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Ms. Menon was found.
Tobias Rennert (General Counsel, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Mr. Rennert was found.
Sandra Yee (VP, Content Acquisition, StreamNow): No current or former representation identified. No prior relationship of any kind between the Firm and Ms. Yee was found.
C. Adverse Parties — Meridian Digital Distributors, LLC / Franklin Ogilvie
Meridian Digital Distributors, LLC: No current or former representation of MDD was identified in the System. The Firm has not acted for or against MDD in any matter. The System returned no matches for "Meridian Digital Distributors, LLC," "Meridian Digital Distributors," or "Meridian Digital."
Franklin Ogilvie: No current or former representation of Mr. Ogilvie was identified in the System. No prior relationship of any kind between the Firm and Mr. Ogilvie was found. It is noted, for purposes of this memorandum, that Mr. Ogilvie is a former employee of Aurelius Media Americas, Inc., having served as a licensing manager from approximately 2017 through June 30, 2021. According to information provided by Ms. Hartwell, Mr. Ogilvie's separation agreement dated June 30, 2021 included covenants relating to non-competition, non-solicitation, and prohibitions on the use of Aurelius's intellectual property and confidential information. Aurelius alleges that Mr. Ogilvie, through MDD, facilitated the sublicensing of Aurelius-owned content to StreamNow in breach of these obligations. Although Mr. Ogilvie's former employment relationship with the prospective client is relevant to the underlying merits of the dispute, it does not give rise to any conflict-of-interest issue for the Firm, as Calderwood & Harkness has never represented Mr. Ogilvie in any capacity.
D. StreamNow Investor — Pinnacle Ventures
Pinnacle Ventures Fund III, LP: No current or former representation of Pinnacle Ventures Fund III, LP was identified in the System. The Firm has not acted for or against this entity in any capacity.
Pinnacle Ventures Management III, LLC: No current or former representation of Pinnacle Ventures Management III, LLC was identified in the System. The Firm has not acted for or against this entity in any capacity.
Howard Cheng (Managing Partner, Pinnacle Ventures): No current or former representation of Mr. Cheng was identified in the System. No prior relationship of any kind between the Firm and Mr. Cheng was found.
The search for Pinnacle Ventures-related entities included variations of the "Pinnacle Ventures" name (including "Pinnacle Ventures," "Pinnacle Fund," "Pinnacle Capital," "Pinnacle Partners," and "Pinnacle Management") and was cross-checked against the Firm's fund/investment client index, which catalogs all venture capital, private equity, and investment fund clients and counterparties. No hits were returned from any of these searches.
E. StreamNow's Outside Counsel — Grantham Roth & Pearce LLP
Grantham Roth & Pearce LLP: No current or former co-counsel or opposing counsel relationship was identified in the System that would create a conflict or give rise to any concern. While Grantham Roth & Pearce is a well-established litigation firm in the Los Angeles legal market and its attorneys may have appeared in matters involving Calderwood & Harkness attorneys in the ordinary course, no specific matter was identified in which the two firms served as co-counsel, opposing counsel, or otherwise had a relationship that would implicate any conflict-of-interest rule or create an appearance of impropriety.
Victoria Langford (Partner, IP Litigation, Grantham Roth & Pearce): No prior opposing counsel or co-counsel relationship with any Calderwood & Harkness attorney was identified.
Brian Matsuda (Associate, Grantham Roth & Pearce): No prior opposing counsel or co-counsel relationship with any Calderwood & Harkness attorney was identified.
F. FAST Channel Sublicensees
Brindoval Channel Networks, Inc. (Dallas, Texas): No current or former representation identified in the System. The Firm has not acted for or against this entity.
BrightLoop Media, LLC (Miami, Florida): No current or former representation identified in the System. The Firm has not acted for or against this entity.
Velvet Stream Partners, LP (Toronto, Ontario, Canada): No current or former representation identified in the System. The Firm has not acted for or against this entity.
Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia): No current or former representation identified in the System. The Firm has not acted for or against this entity.
G. Client's Other Advisors and Related Third Parties
Bexley Marsh Solicitors LLP: No current or former relationship was identified in the System that would create a conflict. Bexley Marsh is serving as Aurelius's UK outside intellectual property counsel in connection with the same underlying dispute. Calderwood & Harkness's proposed engagement is complementary — the Firm would serve as U.S. litigation counsel — and no conflict arises from the concurrent representation of the same client by two separate law firms in different jurisdictions. No adverse relationship with Bexley Marsh was identified.
Whitmore & Pryce LLP: No current or former relationship identified in the System. Whitmore & Pryce's role as Aurelius's external auditor does not give rise to any conflict for the Firm.
Fortbridge Specialty Insurance Company: No current or former representation of Fortbridge Specialty Insurance Company was identified in the System. The Firm has not acted for or against Fortbridge. As Aurelius's media liability and intellectual property enforcement insurer under Policy No. FSI-ML-2024-07821, Fortbridge may be notified of the proposed litigation and may have certain rights under the policy, but no adversity between Calderwood & Harkness and Fortbridge is anticipated. If coverage issues arise during the course of the engagement, the analysis will be revisited at that time.
Calder & Whitfield Insurance Brokers Ltd.: No current or former representation identified in the System. No relationship of any kind between the Firm and Calder & Whitfield was found.
Capitol Registered Agents, Inc.: No current or former representation identified in the System. Capitol Registered Agents serves only as the statutory registered agent for service of process for StreamNow Holdings, Inc. in the State of Delaware and has no substantive involvement in the underlying dispute.
H. Proposed Expert Consultants
CipherTrace Analytics, LLC / Dr. Nathan Frey: No conflicts identified. The System returned no matches for CipherTrace Analytics, LLC or for Dr. Nathan Frey. CipherTrace has not been retained by any adverse party in this matter or in any related matter within the Firm's records. Dr. Frey has not appeared as an expert, consultant, or party in any matter adverse to a Calderwood & Harkness client.
Lexington IP Services, Inc. / Marissa Chung: No conflicts identified. The System returned no matches for Lexington IP Services, Inc. or for Marissa Chung. No prior engagement of Lexington by any adverse party was found.
Hargrove Economic Consulting Group, LLC / Dr. Elena Vasquez: No conflicts identified. The System returned no matches for Hargrove Economic Consulting Group, LLC or for Dr. Elena Vasquez. No prior engagement of Hargrove by any adverse party was found. It is noted that Hargrove has already performed preliminary damages analysis for Aurelius in connection with this matter and has produced the $41.3 million preliminary damages estimate referenced in Section II above, which does not create any conflict for the Firm.
VI. Analysis of Potential Issues
In addition to the database search results set forth in Section V, the following analysis addresses specific categories of potential conflicts and ethical issues that were considered in connection with the Proposed Engagement.
A. No Duty of Loyalty Conflicts
Calderwood & Harkness owes no existing duty of loyalty to StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, Pinnacle Ventures Fund III, LP, Pinnacle Ventures Management III, LLC, any of the four FAST channel sublicensees (Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd), or any individual officer, director, employee, or agent associated with any of those entities. None of these parties is a current client of the Firm. Accordingly, the Firm's representation of Aurelius against these parties does not implicate California Rule of Professional Conduct 1.7(a) (prohibiting representation directly adverse to a current client) or 1.7(b) (prohibiting representation where there is a significant risk that the representation will be materially limited by the lawyer's responsibilities to another client, a former client, or a third person, or by a personal interest of the lawyer).
B. No Business Transaction / Personal Interest Conflicts
No partner, counsel, or associate at the Firm has disclosed any financial interest in StreamNow Holdings, Inc., Pinnacle Ventures Fund III, LP, Pinnacle Ventures Management III, LLC, Meridian Digital Distributors, LLC, or any entity related to any of the prospective adverse parties. A supplemental inquiry was made of all partners in the Firm's Los Angeles and San Francisco offices, consistent with Firm Policy No. 2019-COI-003, Section 4.3 (requiring affirmative disclosure of personal financial interests in adverse parties). All responses were negative. No partner holds investments in Pinnacle Ventures Fund III, LP or any other Pinnacle Ventures-managed fund. Accordingly, no personal interest conflict under California Rule of Professional Conduct 1.7(b) exists.
C. No Former Client Conflicts
The Firm has no former client relationships that would be substantially related to the subject matter of the Aurelius-StreamNow copyright infringement dispute. The System search confirmed that neither StreamNow nor any of the other adverse parties has ever been a client of the Firm. No former client matter was identified in which the confidential information obtained during the prior representation could be used to the disadvantage of a former client in this engagement. Accordingly, no conflict under California Rule of Professional Conduct 1.9 (Duties to Former Clients) exists. Similarly, no lawyer at the Firm has previously represented any of the adverse parties or their affiliates in a matter substantially related to this engagement while employed at a prior firm, and no imputation issue under California Rule of Professional Conduct 1.10 has been identified.
D. No Co-Counsel / Former Opposing Counsel Issues
Grantham Roth & Pearce LLP, which is anticipated to serve as StreamNow's outside litigation counsel in the Proposed Engagement, has not served as co-counsel with, or opposing counsel to, Calderwood & Harkness in any matter that would give rise to a conflict of interest or create an appearance of impropriety. While individual attorneys at both firms may have participated in matters involving the other firm in the ordinary course of practice in the Los Angeles legal market, no specific matter was identified that would implicate any ethical rule or create any concern regarding the Firm's ability to represent Aurelius zealously and without divided loyalty.
E. New Client Intake
Aurelius Global Media Group PLC is a new client for Calderwood & Harkness LLP. The Firm has not previously represented Aurelius or any of its subsidiaries, affiliates, officers, or directors. Standard new client intake procedures must be completed before the engagement is formally opened. Given that Aurelius is a public limited company incorporated in England and Wales, the intake procedures will include Know Your Customer ("KYC") and Anti-Money Laundering ("AML") due diligence requirements applicable to UK-incorporated entities, consistent with Firm Policy No. 2021-KYC-001 (Client Identification and Verification for International Clients). Verification of the authority of Fiona Hartwell to engage Calderwood & Harkness on behalf of Aurelius and its subsidiaries will also be completed as part of the engagement letter process. It is anticipated that the KYC/AML review and authority verification will be conducted concurrently with the finalization and execution of the engagement letter.
VII. Conclusion and Clearance
Based on the comprehensive results of the conflict-of-interest check conducted across all Calderwood & Harkness offices and databases, as documented in this memorandum, no conflicts of interest have been identified that would preclude Calderwood & Harkness LLP from representing Aurelius Global Media Group PLC and its wholly-owned subsidiary, Aurelius Media Americas, Inc., in connection with the pre-suit copyright infringement assessment, demand, and potential litigation against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and related parties, as described herein (Matter No. 1017-00003).
The engagement is cleared to proceed.
The following steps should be taken to formalize the engagement:
1.  The engagement letter should be finalized in accordance with the Firm's standard form for new client litigation engagements, incorporating any client-specific terms discussed during the initial consultation with Ms. Hartwell, and transmitted to Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC, for review and execution.
2.  It is recommended that the matter be formally opened in the Firm's matter management system upon receipt of the fully executed engagement letter and the initial retainer deposit of $150,000, as discussed with Ms. Hartwell during the January 15, 2026 consultation.
3.  New client intake procedures, including KYC/AML due diligence for Aurelius as a UK-incorporated public limited company and verification of Ms. Hartwell's authority to engage the Firm, should be completed concurrently with the engagement letter process.
4.  Upon formal opening of the matter, a supplemental conflict check should be conducted if and when additional parties, witnesses, or related entities are identified during the course of the pre-suit investigation and any subsequent litigation.
VIII. Approval
Prepared by:
________________________________________
Wendy Schultz Senior Associate, intellectual Property Calderwood & Harkness LLP — Los Angeles Office
Date: February 10, 2026
Reviewed and Approved by:
________________________________________
Marcus Delgado Partner, intellectual Property Calderwood & Harkness LLP — Los Angeles Office
Date: February 10, 2026
Engagement Cleared:  Yes
APPENDIX A
Summary Table of Parties Searched and Results
The following table sets forth all thirty-one (31) parties and individuals searched in connection with the conflict check for Matter No. 1017-00003, together with the entity type, role in the matter, date of initial search, and result.
End of Memorandum — Matter No. 1017-00003 Calderwood & Harkness LLP — Privileged & Confidential — Attorney Work Product
FROM: | Wendy Schultz, Senior Associate, intellectual Property
TO: | Marcus Delgado, Partner, intellectual Property
CC: | Catherine Bloom, Partner, intellectual Property
DATE: | February 10, 2026
RE: | Conflict of Interest Check — Proposed Representation of Aurelius Global Media Group PLC — Matter No. 1017-00003
No. | Party / Individual | Entity Type | Role in Matter | Date Searched | Result
1 | Aurelius Global Media Group PLC | Public limited company (England & Wales) | Client | Jan. 16, 2026 | No Conflict
2 | Aurelius Media Americas, Inc. | Delaware corporation | Client (subsidiary) | Jan. 16, 2026 | No Conflict
3 | Sir Alistair Pemberton | Individual | Client officer (CEO) | Jan. 16, 2026 | No Conflict
4 | Fiona Hartwell | Individual | Client officer (GC) | Jan. 16, 2026 | No Conflict
5 | Raj Anantharam | Individual | Client officer (SVP) | Jan. 16, 2026 | No Conflict
6 | Lena Kowalski | Individual | Client officer (Head of DRE) | Jan. 16, 2026 | No Conflict
7 | StreamNow Holdings, Inc. | Delaware corporation | Adverse / Prospective Defendant | Jan. 16, 2026 | No Conflict
8 | Derek Calloway | Individual | Adverse (CEO, StreamNow) | Jan. 16, 2026 | No Conflict
9 | Priya Menon | Individual | Adverse (COO, StreamNow) | Jan. 16, 2026 | No Conflict
10 | Tobias Rennert | Individual | Adverse (GC, StreamNow) | Jan. 16, 2026 | No Conflict
11 | Sandra Yee | Individual | Adverse (VP, StreamNow) | Jan. 16, 2026 | No Conflict
12 | Meridian Digital Distributors, LLC | California LLC | Adverse / Prospective Defendant | Jan. 16, 2026 | No Conflict
13 | Franklin Ogilvie | Individual | Adverse (Member/Mgr., MDD) | Jan. 16, 2026 | No Conflict
14 | Pinnacle Ventures Fund III, LP | Delaware LP | Related (StreamNow investor) | Jan. 30, 2026 | No Conflict
15 | Pinnacle Ventures Management III, LLC | Delaware LLC | Related (GP of Fund III) | Jan. 30, 2026 | No Conflict
16 | Howard Cheng | Individual | Related (MP, Pinnacle) | Jan. 30, 2026 | No Conflict
17 | Grantham Roth & Pearce LLP | Law firm (CA) | Opposing counsel | Jan. 30, 2026 | No Conflict
18 | Victoria Langford | Individual | Opposing counsel (Partner) | Jan. 30, 2026 | No Conflict
19 | Brian Matsuda | Individual | Opposing counsel (Associate) | Jan. 30, 2026 | No Conflict
20 | Brindoval Channel Networks, Inc. | Corporation (TX) | Potential additional adverse | Jan. 30, 2026 | No Conflict
21 | BrightLoop Media, LLC | LLC (FL) | Potential additional adverse | Jan. 30, 2026 | No Conflict
22 | Velvet Stream Partners, LP | LP (ON, Canada) | Potential additional adverse | Jan. 30, 2026 | No Conflict
23 | Pacific Lantern Digital Pty Ltd | Pty Ltd (NSW, Australia) | Potential additional adverse | Jan. 30, 2026 | No Conflict
24 | Bexley Marsh Solicitors LLP | Law firm (UK) | Client's UK IP counsel | Jan. 30, 2026 | No Conflict
25 | Whitmore & Pryce LLP | Accounting firm (UK) | Client's auditor | Jan. 30, 2026 | No Conflict
26 | Fortbridge Specialty Insurance Co. | Insurance company (CT) | Client's insurer | Jan. 30, 2026 | No Conflict
27 | Calder & Whitfield Insurance Brokers Ltd. | Insurance broker (UK) | Client's broker | Jan. 30, 2026 | No Conflict
28 | CipherTrace Analytics, LLC | LLC (CA) | Proposed expert (forensics) | Feb. 7, 2026 | No Conflict
29 | Lexington IP Services, Inc. | Corporation (DC) | Proposed expert (copyright) | Feb. 7, 2026 | No Conflict
30 | Hargrove Economic Consulting Group, LLC | LLC (CA) | Proposed expert (damages) | Feb. 7, 2026 | No Conflict
31 | Capitol Registered Agents, Inc. | Corporation (DE) | Related (registered agent) | Feb. 7, 2026 | No Conflict

MEMORANDUM — PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT

CALDERWOOD & HARKNESS LLP

APPENDIX A

Record

Parties

Dates

Amounts