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

litigation-hold-notice.docx DOCUMENT Litigation

15 / 37 ← → ✕

CALDERWOOD & HARKNESS LLP Attorneys at Law

Los Angeles Office 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 557-4200 Facsimile: (310) 557-4201

New York Office 600 Lexington Avenue New York, New York 10022 Telephone: (212) 848-6300 Facsimile: (212) 848-6301

www.calderwoodharkness.com

VIA EMAIL AND OVERNIGHT COURIER

PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION SUBJECT TO ATTORNEY WORK PRODUCT DOCTRINE

February 14, 2026

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

Copy to: Aurelius Media Americas, Inc.

Attn: Office of the General Counsel

1900 Avenue of the Stars, Suite 2200 Los Angeles, California 90067

Re: Litigation Hold Notice — Preservation of Documents and Electronically Stored Information

Matter: Aurelius Global Media Group PLC — Pre-Suit Copyright Infringement Assessment re StreamNow Holdings, Inc. et al.

Matter No.: 1017-00003

Dear Ms. Hartwell:

I. Purpose and Legal Obligation

Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG") and its wholly-owned subsidiary Aurelius Media Americas, Inc. ("AMA") in connection with potential copyright infringement claims against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie, among other potential parties yet to be identified. This engagement encompasses the investigation, evaluation, and prosecution of claims arising from the unauthorized reproduction, distribution, and public performance of Aurelius-owned audiovisual content through StreamNow's streaming platform and sublicensed channels.

This letter constitutes a formal litigation hold notice directing Aurelius and AMA to immediately identify, preserve, and refrain from destroying, altering, discarding, or otherwise disposing of any and all documents, communications, and electronically stored information ("ESI") that are potentially relevant to the claims and defenses in the anticipated litigation described herein. This obligation extends to all forms of tangible and intangible information, in whatever medium or format they may exist, as more fully described below.

Litigation is reasonably anticipated. Calderwood & Harkness was formally engaged on February 12, 2026, to represent Aurelius and AMA in this matter. Based on counsel's assessment of the facts and applicable law, Aurelius intends to serve a formal cease-and-desist letter and pre-suit demand upon StreamNow in March 2026. If settlement discussions do not result in a satisfactory resolution, Aurelius intends to file a complaint in the United States District Court for the Central District of California no later than June 2026. Claims will include, without limitation, copyright infringement under 17 U.S.C. §§ 106, 501, and related provisions, as well as claims for contributory and vicarious infringement, civil conspiracy, and violation of the Digital Millennium Copyright Act.

The duty to preserve relevant evidence attaches at the point when litigation is reasonably anticipated, which, in light of the foregoing, has now clearly occurred. Both Aurelius and AMA bear an affirmative obligation to ensure that all potentially relevant materials are identified, secured, and maintained in their current form. Failure to comply with this preservation obligation may result in severe legal consequences. Under Federal Rule of Civil Procedure 37(e), a court may order measures up to and including adverse inference instructions, evidentiary sanctions, monetary penalties, or default judgment if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the lost information cannot be restored or replaced through additional discovery. Courts have imposed similar sanctions for the destruction of hard copy documents and other tangible materials. Aurelius's and AMA's credibility before the court may be irreparably damaged by any failure to preserve relevant evidence.

This notice is intended to ensure that Aurelius and AMA take all reasonable steps to comply with their legal obligations. We ask that you treat this matter with the utmost urgency and seriousness.

II. Background Summary

To provide context for the scope of the preservation obligation, we summarize below the factual background giving rise to the anticipated litigation.

Aurelius Global Media Group PLC is a United Kingdom–based media conglomerate that owns an extensive library of copyrighted audiovisual content. Aurelius's content library encompasses over 4,200 film and television titles, including some of the most commercially successful and critically acclaimed properties in contemporary entertainment. Among the crown jewels of this library are the "Meridian" franchise, consisting of six feature films with a combined global box office of approximately $1.43 billion; the "Iron Compass" series, a critically acclaimed four-season, 48-episode drama that averaged 9.2 million UK viewers per episode during its original broadcast run; and the "Thornfield" period drama catalog, which includes 12 titles and has been honored with 7 BAFTA awards.

Through its ongoing content monitoring and digital rights enforcement efforts, Aurelius has identified that StreamNow Holdings, Inc. — a Delaware corporation (File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010 — has, without authorization from Aurelius or any authorized representative of Aurelius, reproduced, distributed, and publicly performed at least 217 Aurelius-owned audiovisual works through its proprietary streaming platform and sublicensed distribution channels. The 217 works at issue consist of 142 feature films and 75 television series comprising a total of 1,038 individual episodes. The unauthorized exploitation occurred over an approximately 22-month period, from on or about April 1, 2024, through at least January 31, 2026, and may be continuing.

StreamNow claims to have obtained distribution rights to the Aurelius titles through a purported Content Distribution Agreement dated March 15, 2024, entered into with Meridian Digital Distributors, LLC (California Secretary of State File No. 202115729430). MDD is a company owned and operated by Franklin Ogilvie, a former mid-level licensing manager at Aurelius Media Americas, Inc. Ogilvie's employment with AMA terminated on June 30, 2021, following an internal investigation into his unauthorized access to Aurelius's content management systems and misuse of proprietary information. Ogilvie's separation agreement, executed on June 30, 2021, contains express non-compete, non-solicitation, and intellectual property usage prohibitions.

Aurelius's records confirm unequivocally that it has never granted MDD, Franklin Ogilvie, or any entity controlled by or affiliated with Ogilvie any license, sublicense, distribution authority, or other right of any kind with respect to any Aurelius-owned content. The purported Content Distribution Agreement between MDD and StreamNow is therefore without any legitimate basis, and the distribution of Aurelius content thereunder constitutes willful copyright infringement.

The scope of the infringement is not limited to StreamNow's own platform. Our investigation has revealed that StreamNow also sublicensed content bundles containing Aurelius titles to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators: (1) Brindoval Channel Networks, Inc. (Dallas, Texas); (2) BrightLoop Media, LLC (Miami, Florida); (3) Velvet Stream Partners, LP (Toronto, Ontario, Canada); and (4) Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia). The unauthorized distribution through these additional channels has compounded the harm to Aurelius and broadened the geographic scope of the infringement.

Based on publicly available financial data, industry estimates, and preliminary analysis by Aurelius's finance team, the estimated revenue attributable to StreamNow's unauthorized exploitation of Aurelius-owned content during the infringement period is approximately $38.6 million. This figure does not account for additional revenue earned by the four FAST channel operators or the broader market harm to Aurelius's licensing program.

The infringement was first discovered by Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, on October 15, 2025, during routine content monitoring operations. Ms. Kowalski escalated the matter to Fiona Hartwell, General Counsel, on October 22, 2025. An internal investigation was commenced at that time, initially in coordination with Bexley Marsh Solicitors LLP, Aurelius's UK outside counsel, who were engaged on November 18, 2025. On November 3, 2025, during the investigation, Sandra Yee, StreamNow's Vice President of Content Acquisition, sent an email to Raj Anantharam, Aurelius's SVP of Content Licensing & Distribution, claiming that MDD possessed valid sublicense authority. This communication is inconsistent with Aurelius's records and is a critical piece of evidence in the anticipated litigation.

III. Scope of Preservation Obligation

The preservation obligation set forth in this notice is intentionally broad in order to ensure that all potentially relevant materials are captured and preserved. The scope of the hold is defined by reference to the persons and entities covered, the applicable time period, and the subject matter categories described below.

A. Persons and Entities Covered

This litigation hold applies to Aurelius Global Media Group PLC (Companies House Registration No. 08724561) and all of its subsidiaries and affiliates, including specifically and without limitation Aurelius Media Americas, Inc. (a Delaware corporation). The hold extends to all officers, directors, employees, contractors, consultants, temporary workers, interns, and agents of Aurelius and AMA who may possess, have access to, or have custody or control over documents or ESI that fall within the scope of this hold. This includes individuals at all levels of the organization, regardless of title, department, or geographic location.

Key custodians who must be notified immediately and who bear heightened preservation responsibilities are identified in Section VII below. However, the preservation obligation is not limited to those specific individuals. Any person within the Aurelius organization who becomes aware that he or she possesses relevant materials must take immediate steps to preserve those materials and notify the designated litigation hold coordinator.

B. Time Period

All documents and ESI created, sent, received, modified, or stored from January 1, 2016, through the present date and continuing must be preserved. The hold will remain in effect on a continuing, forward-looking basis until it is formally released in writing by Calderwood & Harkness LLP.

This time period has been selected to encompass, with appropriate margins, the following critical phases of the factual narrative:

• Franklin Ogilvie's employment at Aurelius Media Americas, Inc. (approximately 2017 through June 30, 2021);

• The internal investigation leading to Ogilvie's separation from AMA (2021);

• The formation of Meridian Digital Distributors, LLC (late 2021);

• The execution of the purported Content Distribution Agreement between MDD and StreamNow (March 15, 2024);

• The full infringement period during which Aurelius content was unauthorized streamed and sublicensed (April 1, 2024, through January 31, 2026);

• The discovery of the unauthorized streaming by Lena Kowalski (October 15, 2025);

• The escalation to Fiona Hartwell and commencement of the internal investigation (October 22, 2025);

• The engagement of Bexley Marsh Solicitors LLP (November 18, 2025); and

• All subsequent investigation, remediation, and litigation preparation activity through the present and continuing.

The January 1, 2016, start date also captures any pre-employment background or communications relating to Ogilvie that may predate the commencement of his employment, as well as any historical licensing and distribution records for the 217 titles that may be relevant to establishing ownership, chain of title, and fair market value.

C. Subject Matter Categories

Documents and ESI must be preserved if they relate to any of the following subject matter categories. These categories should be construed broadly, and any doubt as to whether a particular document or item of ESI falls within the scope of the hold should be resolved in favor of preservation.

1. The 217 Works at Issue. All documents relating to the creation, production, acquisition, ownership, copyright registration, licensing, distribution, and exploitation of each of the 217 audiovisual titles identified in the enclosed List of 217 Titles Subject to Litigation Hold. This includes, without limitation, all documents specifically relating to the Meridian franchise (six feature films), the Iron Compass series (four seasons, 48 episodes), and the Thornfield period drama catalog (12 titles). This category encompasses production agreements, chain-of-title documents, work-for-hire agreements, assignment agreements, acquisition agreements, co-production agreements, and any other documentation establishing or affecting Aurelius's ownership interest in the works.

2. Copyright Registrations. All U.S. Copyright Office registration certificates, applications, correspondence with the Copyright Office, recordation documents, and chain-of-title documentation for each of the 217 titles at issue. This includes the 189 titles for which timely copyright registrations were filed prior to the commencement of infringement, as well as the 28 titles for which registrations postdate the commencement of infringement. All supporting documentation submitted in connection with such registrations must also be preserved.

3. StreamNow Holdings, Inc. All communications, correspondence, documents, agreements, memoranda, and ESI of any kind that relate to, reference, or mention StreamNow Holdings, Inc., or any of the following individuals in their capacity as StreamNow officers, employees, agents, or representatives: Derek Calloway (Chief Executive Officer), Priya Menon (Chief Operating Officer), Tobias Rennert (General Counsel), Sandra Yee (Vice President, Content Acquisition), and any other StreamNow employee, agent, or representative with whom any Aurelius or AMA personnel have communicated. This includes, without limitation, the November 3, 2025, email from Sandra Yee to Raj Anantharam and any response thereto.

4. Meridian Digital Distributors, LLC. All communications, documents, agreements, and ESI relating to or referencing Meridian Digital Distributors, LLC, including any purported license, sublicense, distribution agreement, content supply agreement, or other arrangement of any kind, whether executed or merely proposed, between MDD and any party. This also includes any documents reflecting Aurelius's or AMA's awareness of or investigation into MDD's activities.

5. Franklin Ogilvie. All personnel records, employment agreements (including any offer letters, employment contracts, and amendments), the separation agreement dated June 30, 2021 (including all exhibits and attachments, specifically including the non-compete, non-solicitation, and intellectual property usage prohibitions contained therein), performance reviews, internal investigation files, disciplinary records, warnings, and any other HR records relating to Ogilvie. This category also includes all access logs documenting Ogilvie's use of Aurelius's content management systems, digital asset management platforms, and other internal systems during and after his employment. Any post-separation communications with, about, or referencing Ogilvie must also be preserved, including any communications between Aurelius/AMA personnel and Ogilvie, or any third-party communications referencing Ogilvie's activities after his departure.

6. Authorized Licensing and Distribution. All existing and historical license agreements, distribution agreements, content supply agreements, output deals, and other agreements pursuant to which Aurelius has authorized the exploitation of any of the 217 titles at issue, regardless of the platform, territory, or medium. This includes comparable arm's-length license agreements for the same or similar titles that may be used for fair market value benchmarking in connection with damages calculations. Revenue reports, minimum guarantees, and royalty accounting under such agreements must also be preserved.

7. Internal Investigation (2021). All documents relating to the internal investigation of Franklin Ogilvie's unauthorized access to and misuse of Aurelius's content management systems conducted in 2021, including without limitation investigation reports, memoranda, forensic analysis reports, interview notes, witness statements, email reviews, system access audits, and any communications with Bexley Marsh Solicitors LLP (Aurelius's UK outside counsel) relating to the investigation and Ogilvie's separation. Any documents reflecting remedial measures taken by Aurelius or AMA following the investigation must also be preserved.

8. Discovery of Infringement and Subsequent Investigation. All documents and communications from October 15, 2025, onward relating to Lena Kowalski's discovery of Aurelius titles on the StreamNow platform, the escalation of the matter to Fiona Hartwell on October 22, 2025, the commencement and progress of the internal investigation, any informal or formal communications with StreamNow (including the November 3, 2025, email from Sandra Yee asserting MDD sublicense authority), the engagement of Bexley Marsh Solicitors LLP on November 18, 2025, and the subsequent engagement of Calderwood & Harkness LLP on February 12, 2026. All investigation reports, forensic analyses, content audits, and memoranda generated during the investigation must be preserved.

9. Revenue and Financial Data. All financial records, revenue reports, royalty statements, sales reports, accounting records, internal financial projections, budgets, and financial analyses relating to revenue generated from the 217 titles at issue during the relevant period (January 1, 2016, through the present). This includes licensing revenue received by Aurelius from authorized distributors, viewership and audience data for the 217 titles, advertising revenue data, and any evidence of revenue displacement, lost licensing opportunities, market harm, or diminution of the value of Aurelius's content library attributable to the unauthorized exploitation. Any internal analyses estimating the $38.6 million in revenue attributable to StreamNow's unauthorized exploitation must also be preserved.

10. FAST Channel Operators. All documents, communications, and ESI relating to Brindoval Channel Networks, Inc. (Dallas, Texas), BrightLoop Media, LLC (Miami, Florida), Velvet Stream Partners, LP (Toronto, Ontario, Canada), and Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia), including any communications regarding the sublicensing of Aurelius content to or through these entities, any license agreements or content supply agreements between StreamNow and these entities, and any information regarding the exploitation of Aurelius titles by these entities.

11. Insurance. All documents relating to the Fortbridge Specialty Insurance Company media liability and IP enforcement insurance policy (Policy No. FSI-ML-2024-07821), including the policy itself, all endorsements, riders, and amendments, all correspondence with Fortbridge Specialty Insurance Company, all correspondence with Calder & Whitfield Insurance Brokers Ltd. (Aurelius's insurance broker), and any claims, notices, or coverage requests submitted or contemplated in connection with the present matter. Premium payment records and renewal correspondence should also be preserved.

IV. Types of Materials to Be Preserved

The preservation obligation extends to all forms of documents and information, regardless of the medium, format, or location in which they are stored. The following categories provide guidance but are not intended to be exhaustive. When in doubt, preserve.

A. Electronically Stored Information (ESI)

ESI constitutes the largest and most critical category of potentially relevant materials. The following types of ESI must be preserved:

(a) Email. All email communications on all email systems used by Aurelius and AMA, including corporate email systems (whether hosted on-premises or in the cloud), archived email, journaled email, personal email accounts (such as personal Northgate Software, Cascade Health IT, Ridgeline Technologies, or other webmail accounts) to the extent they were used for business purposes relating to any of the subject matter categories described above, and any email accounts maintained on behalf of departed employees. All attachments to emails must be preserved along with the parent messages. Calendar entries, meeting invitations, task items, and contact records associated with email systems must also be preserved. Email metadata — including sender, recipient, date/time stamps, routing information, read receipts, and folder locations — must be preserved in its native form.

(b) Content Management System ("CMS") Records. All records maintained in Aurelius's and AMA's content management systems, digital asset management platforms, and media asset management systems, including all logs, access records, upload and download records, check-in/check-out records, version histories, metadata, rights management data, and any other data fields associated with the 217 titles at issue. Access control lists, user permission records, and audit trails for CMS systems must be preserved to establish who had access to Aurelius content and what actions were taken with respect to that content.

(c) Licensing Databases. All entries, records, amendments, notes, and audit trails in Aurelius's and AMA's licensing databases, rights management systems, and deal-tracking systems relating to the 217 titles at issue and any relationship — actual, purported, or attempted — with MDD, StreamNow, Franklin Ogilvie, or any of the FAST channel operators identified above.

(d) Internal Messaging Platforms. All communications on internal messaging and collaboration platforms, including without limitation Meridian Solutions, Northgate Data Systems, Meridian Services Inc. (to the extent used for business purposes), signal (to the extent used for business purposes), and any other instant messaging, group chat, or internal communication tools used by Aurelius or AMA personnel.

(e) Shared Drives and Cloud Storage. All documents, files, presentations, spreadsheets, databases, and other materials stored on shared network drives, cloud storage platforms (including Aldermere Systems, Cobalt Ridge Systems, Hollowell Health IT, Larkspur Technologies, box, and similar services), document management systems, and local workstations of key custodians.

(f) Backup Tapes and Disaster Recovery Archives. All backup tapes, disaster recovery archives, and other backup media that may contain relevant data from the preservation period (January 1, 2016, through the present). Backup tapes must not be recycled, overwritten, or destroyed. If backup tapes are subject to rotation schedules that would result in overwriting, those schedules must be immediately suspended for tapes containing data within the scope of this hold.

(g) Website and Intranet Content. All website content, intranet pages, portal content, and online publications referencing the 217 titles at issue or any of the parties identified in this notice.

(h) Mobile Device Data. All data residing on mobile devices (smartphones, tablets, and similar devices) of key custodians, including text messages (SMS and MMS), voicemails, data from messaging applications (including Meridian Services Inc., Signal, Westmark Software, Kestrel Data Systems, and similar applications), call logs, photographs, videos, and notes. Where key custodians use personal mobile devices for business purposes, those devices are subject to this hold to the extent they contain business-related communications within the scope of this notice.

B. Hard Copy Documents

In addition to ESI, all hard copy documents potentially relevant to this matter must be preserved, including without limitation:

(a) Paper files, memoranda, handwritten notes, correspondence, contracts, executed agreements, and printed materials of any kind relating to the subject matter categories described in Section III.C above.

(b) Personnel files and human resources records for Franklin Ogilvie, including his complete employment file maintained by AMA and any records maintained by Aurelius's London headquarters.

(c) Board of directors minutes, executive committee minutes, audit committee minutes, and any other corporate governance records that reference or relate to any of the subject matter categories described above, including any board-level discussions of the StreamNow infringement, the Ogilvie internal investigation, or the licensing and distribution of the 217 titles.

(d) Any physical correspondence or written communications received from or sent to StreamNow, MDD, Franklin Ogilvie, or any of the FAST channel operators.

C. Audio/Visual Materials

(a) Recordings of meetings, presentations, conferences, interviews, or other events relevant to the subject matter categories described above, whether in audio, video, or combined format, and regardless of the recording medium.

(b) Copies of the 217 audiovisual works at issue in all formats maintained by Aurelius or AMA, including master copies, distribution copies, screening copies, and promotional materials. All versions, edits, and formats must be preserved.

V. Prohibition on Destruction, Alteration, or Concealment

Effective immediately upon receipt of this notice, Aurelius and AMA must suspend all routine document destruction, recycling, and deletion policies as they pertain to any documents or ESI within the scope of this litigation hold. This suspension applies to all document retention and destruction schedules, records management policies, clean-desk policies, and any other policies or practices that could result in the destruction, deletion, overwriting, or loss of relevant materials.

No documents or ESI within the scope of this hold may be destroyed, deleted, overwritten, modified, altered, moved, relocated, concealed, or otherwise disposed of, whether in the ordinary course of business or otherwise. This prohibition applies regardless of whether the destruction or alteration would occur as part of routine business operations, IT maintenance, system upgrades, office moves, personnel transitions, or any other activity.

Auto-delete policies on email systems, messaging platforms, collaboration tools, backup systems, and any other data repositories must be immediately suspended for all key custodians identified in Section VII and for any systems or repositories containing potentially relevant data. This includes, without limitation, auto-archiving and auto-deletion settings in Strathmore Data Systems, Ashgrove Software, Crestline Software, Meridian Solutions, Northgate Data Systems, and any other platforms in use by Aurelius or AMA.

The Information Technology departments at both Aurelius (London) and AMA (Los Angeles) must be immediately instructed to implement technical measures to prevent the automated deletion, overwriting, or modification of any data within the scope of this hold. This includes placing legal holds on relevant mailboxes, suspending backup tape rotation schedules, disabling auto-deletion settings, and implementing any other technical safeguards necessary to ensure preservation.

Any employee, contractor, or agent who becomes aware of the actual or threatened destruction, alteration, or loss of materials within the scope of this hold must immediately report the situation to Fiona Hartwell, the designated litigation hold coordinator, and Calderwood & Harkness LLP.

VI. IT Coordination

The effective implementation of this litigation hold requires close coordination between Aurelius's and AMA's IT departments and outside counsel. Accordingly, the IT departments at Aurelius (London) and AMA (Los Angeles) should be directed to take the following actions immediately:

(a) Identify and Preserve Backup Tapes and Archives. Identify all backup tapes, disaster recovery archives, and other backup media containing data from January 1, 2016, through the present. All such media must be sequestered and preserved. No backup tapes containing data within the preservation period may be recycled, overwritten, or destroyed.

(b) Suspend Auto-Deletion and Data Retention Cycling. Suspend all automatic deletion settings, data retention cycling policies, and scheduled purges for all identified key custodians and all data repositories that may contain relevant information. This includes but is not limited to email systems, collaboration platforms, shared drives, cloud storage, CMS platforms, licensing databases, and backup systems.

(c) Preserve CMS Access Logs and Audit Trails. Preserve all content management system access logs and audit trails in their native format, with full metadata intact. These logs are essential to establishing the chain of events surrounding Ogilvie's access to Aurelius content and the unauthorized distribution of that content. No access logs should be purged, truncated, or modified.

(d) Forensic Imaging. Image or create forensic copies of relevant workstations, laptops, mobile devices, and server directories as directed by counsel. Forensic images should be created using industry-standard forensic tools and procedures to ensure the integrity and admissibility of the data. Chain of custody documentation must be maintained for all forensic images.

(e) Coordination with CipherTrace Analytics, LLC. Coordinate with Calderwood & Harkness LLP and, as necessary, with CipherTrace Analytics, LLC, Calderwood & Harkness's retained digital forensics expert, for any required forensic preservation, data extraction, or analysis. CipherTrace Analytics is led by Dr. Nathan Frey and is located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. Dr. Frey and his team may need direct access to Aurelius and AMA systems and personnel to conduct forensic preservation work. All such access will be coordinated through Calderwood & Harkness and the designated litigation hold coordinator.

Calderwood & Harkness will schedule a technical coordination call with Aurelius's and AMA's IT leadership within one week of the date of this notice to discuss the specific technical steps required for implementation.

VII. Key Custodians — Immediate Notification Required

The following individuals have been identified as key custodians who are likely to possess documents and ESI within the scope of this litigation hold. Each of these individuals must be notified of the hold immediately and must receive either a copy of this notice or a custodian-specific preservation instruction:

1. Fiona Hartwell — General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell is the recipient of this notice and bears primary responsibility for implementing the litigation hold across the entire Aurelius organization. Ms. Hartwell's own files, communications, and records relating to the StreamNow matter, the Ogilvie investigation, and content licensing are within the scope of the hold.

2. Lena Kowalski — Head of Digital Rights Enforcement, Aurelius Global Media Group PLC. Ms. Kowalski discovered the unauthorized streaming of Aurelius content on the StreamNow platform on October 15, 2025, and is a central witness in the anticipated litigation. All of her files, communications, monitoring reports, investigation notes, and related materials must be preserved.

3. Raj Anantharam — Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC. Mr. Anantharam is the business-side content lead responsible for licensing and distribution of Aurelius titles and is the recipient of the November 3, 2025, email from Sandra Yee at StreamNow. All of his files, communications, licensing records, and related materials must be preserved.

4. Sir Alistair Pemberton — Chief Executive Officer, Aurelius Global Media Group PLC. To the extent Sir Alistair possesses any communications, memoranda, board presentations, or other materials relating to the StreamNow infringement, the Ogilvie investigation, or the licensing and distribution of the 217 titles at issue, all such materials must be preserved.

5. Additional Custodians. Any current or former employees of Aurelius or AMA who had involvement in any of the following matters must also be identified and notified:

(a) The internal investigation of Franklin Ogilvie in 2021;

(b) Ogilvie's employment, supervision, management, or separation from AMA;

(d) The discovery, investigation, and remediation of the StreamNow infringement from October 15, 2025, onward.

6. Heads of Information Technology at Aurelius (London) and AMA (Los Angeles), who must implement the technical preservation measures described in Sections V and VI above.

All custodians should receive a copy of this litigation hold notice or a custodian-specific preservation instruction tailored to their role. Each custodian must acknowledge receipt in writing by signing and returning the enclosed Custodian Acknowledgment Form. Completed acknowledgment forms should be returned to Fiona Hartwell and forwarded to Calderwood & Harkness for our records.

We request that Aurelius provide Calderwood & Harkness with a complete list of all notified custodians, together with their titles, departments, and contact information, within ten (10) business days of the date of this notice.

VIII. Acknowledgment and Compliance

Fiona Hartwell, on behalf of Aurelius Global Media Group PLC and Aurelius Media Americas, Inc., is requested to acknowledge receipt of this litigation hold notice in writing (by email or letter addressed to Marcus Delgado at the Calderwood & Harkness Los Angeles office) within five (5) business days of the date of this notice — that is, no later than February 21, 2026. The acknowledgment should confirm that Aurelius and AMA understand the scope and requirements of the hold, that the hold has been communicated to the relevant personnel, and that steps are being taken to implement the hold.

Aurelius should designate a litigation hold coordinator — an internal point of contact — to oversee day-to-day compliance with the hold and to serve as the primary liaison between Aurelius/AMA and Calderwood & Harkness on all preservation matters. We recommend that this individual be someone with sufficient organizational authority to direct compliance across departments and geographies, and with the technical understanding necessary to coordinate with IT on implementation. We are happy to discuss appropriate candidates for this role at your convenience.

Calderwood & Harkness will issue periodic reminders of this litigation hold to ensure ongoing compliance. As the matter develops, we may supplement, expand, or narrow the scope of this hold in writing. No changes to the scope of the hold will be effective unless communicated in writing by Calderwood & Harkness.

Any questions regarding the scope, interpretation, or implementation of this litigation hold should be directed to:

Marcus Delgado, Partner, intellectual Property Litigation Telephone: (310) 557-4218

Email: m.delgado@calderwoodharkness.com

Wendy Schultz, Senior Associate, intellectual Property Litigation Telephone: (310) 557-4235

Email: w.schultz@calderwoodharkness.com

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

IX. Duration of Hold

This litigation hold remains in effect until further written notice from Calderwood & Harkness LLP. No individual within Aurelius or AMA has the authority to release, modify, or narrow this hold without written authorization from Calderwood & Harkness.

The hold will not be released until the matter described herein is fully and finally resolved, whether by settlement, final judgment (including exhaustion of all appellate rights), voluntary dismissal, or mutual written agreement of the parties, and Calderwood & Harkness provides a formal written release of the hold. Until such a release is issued, all preservation obligations described in this notice remain in full force and effect.

Aurelius and AMA should anticipate that this hold will remain in effect for a substantial period of time, potentially several years, given the complexity of the anticipated litigation and the number of parties and works involved.

X. Consequences of Non-Compliance

We wish to emphasize in the strongest possible terms the seriousness of the preservation obligations described in this notice. Failure to comply with this litigation hold may expose Aurelius and AMA to severe legal consequences, including but not limited to:

• Court-imposed sanctions, including monetary penalties assessed against the company and, in appropriate cases, against individual officers and employees;

• Adverse inference instructions, in which the court instructs the jury that it may presume destroyed evidence was unfavorable to Aurelius — an instruction that can be devastating to the prosecution of Aurelius's claims;

• Preclusion of evidence, in which the court bars Aurelius from introducing evidence on topics for which relevant materials were destroyed;

• Dismissal of claims, in the most extreme cases of willful or bad faith spoliation; and

• Referral for contempt proceedings or other judicial action.

Under Federal Rule of Civil Procedure 37(e), if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the lost information cannot be restored or replaced through additional discovery, the court may: (1) upon finding prejudice to another party from the loss of the information, order measures no greater than necessary to cure the prejudice; or (2) only upon finding that the party acted with the intent to deprive another party of the information's use in the litigation, presume that the lost information was unfavorable to the party, instruct the jury that it may or must presume the information was unfavorable, or dismiss the action or enter a default judgment.

Courts have consistently held that the duty to preserve arises when litigation is reasonably anticipated, and that a party's failure to issue a timely litigation hold or to take affirmative steps to prevent the destruction of relevant evidence may itself constitute evidence of bad faith or willful spoliation. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212 (S.D.N.Y. 2003); Rimkus Consulting Group, Inc. v. Cammarata, 688 F. Supp. 2d 598 (S.D. Tex. 2010).

All personnel who receive this notice or a custodian-specific preservation instruction must understand the seriousness of this obligation and must take immediate, affirmative steps to ensure compliance. Ignorance of the hold is not a defense to a finding of spoliation if reasonable steps to communicate and implement the hold were not taken.

Closing

Calderwood & Harkness LLP is fully available to assist Aurelius and AMA with the implementation of this litigation hold. Our assistance includes, but is not limited to, providing guidance and training to IT staff on technical preservation measures, conducting custodian interviews to identify the location and nature of potentially relevant materials, advising on the scope of the hold as applied to specific custodians or data sources, and coordinating with CipherTrace Analytics, LLC for forensic preservation and data extraction as needed.

We are grateful for Aurelius's prompt attention to this matter and appreciate the seriousness with which your organization is approaching its preservation obligations. The early and thorough implementation of this hold will serve Aurelius's interests well in the anticipated litigation and will position the company to present its strongest possible case.

Please do not hesitate to contact Marcus Delgado or Wendy Schultz at the Calderwood & Harkness Los Angeles office with any questions, concerns, or requests for further guidance.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

Marcus Delgado Partner, intellectual Property Litigation Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 557-4218 Facsimile: (310) 557-4201

Email: m.delgado@calderwoodharkness.com

cc: (via email)

Catherine Bloom, Partner, Calderwood & Harkness LLP Wendy Schultz, Senior Associate, Calderwood & Harkness LLP Omar Siddiqui, Associate, Calderwood & Harkness LLP

Enclosures:

1. List of 217 Titles Subject to Litigation Hold — Copyright Registration Summary Report compiled from Lexington IP Services data, completed January 22, 2026. This report identifies each of the 217 audiovisual works by title, format (feature film or television series), number of episodes (where applicable), U.S. Copyright Office registration number, registration date, and registration status (timely or post-infringement).

2. Custodian Acknowledgment Form — Template for each custodian to sign confirming receipt of this litigation hold notice (or a custodian-specific preservation instruction) and acknowledging their understanding of their preservation obligations. Completed forms should be returned to Fiona Hartwell and forwarded to Calderwood & Harkness LLP.

CALDERWOOD & HARKNESS LLP Attorneys at Law
Los Angeles Office 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 557-4200 Facsimile: (310) 557-4201
New York Office 600 Lexington Avenue New York, New York 10022 Telephone: (212) 848-6300 Facsimile: (212) 848-6301
www.calderwoodharkness.com
VIA EMAIL AND OVERNIGHT COURIER
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION SUBJECT TO ATTORNEY WORK PRODUCT DOCTRINE
February 14, 2026
Fiona Hartwell, Esq. General Counsel Aurelius Global Media Group PLC 45 Clarewood Place London W1K 6TH United Kingdom
Copy to: Aurelius Media Americas, Inc.
Attn: Office of the General Counsel
1900 Avenue of the Stars, Suite 2200 Los Angeles, California 90067
Re: Litigation Hold Notice — Preservation of Documents and Electronically Stored Information
Matter: Aurelius Global Media Group PLC — Pre-Suit Copyright Infringement Assessment re StreamNow Holdings, Inc. et al.
Matter No.: 1017-00003
Dear Ms. Hartwell:
I. Purpose and Legal Obligation
Calderwood & Harkness LLP represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG") and its wholly-owned subsidiary Aurelius Media Americas, Inc. ("AMA") in connection with potential copyright infringement claims against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie, among other potential parties yet to be identified. This engagement encompasses the investigation, evaluation, and prosecution of claims arising from the unauthorized reproduction, distribution, and public performance of Aurelius-owned audiovisual content through StreamNow's streaming platform and sublicensed channels.
This letter constitutes a formal litigation hold notice directing Aurelius and AMA to immediately identify, preserve, and refrain from destroying, altering, discarding, or otherwise disposing of any and all documents, communications, and electronically stored information ("ESI") that are potentially relevant to the claims and defenses in the anticipated litigation described herein. This obligation extends to all forms of tangible and intangible information, in whatever medium or format they may exist, as more fully described below.
Litigation is reasonably anticipated. Calderwood & Harkness was formally engaged on February 12, 2026, to represent Aurelius and AMA in this matter. Based on counsel's assessment of the facts and applicable law, Aurelius intends to serve a formal cease-and-desist letter and pre-suit demand upon StreamNow in March 2026. If settlement discussions do not result in a satisfactory resolution, Aurelius intends to file a complaint in the United States District Court for the Central District of California no later than June 2026. Claims will include, without limitation, copyright infringement under 17 U.S.C. §§ 106, 501, and related provisions, as well as claims for contributory and vicarious infringement, civil conspiracy, and violation of the Digital Millennium Copyright Act.
The duty to preserve relevant evidence attaches at the point when litigation is reasonably anticipated, which, in light of the foregoing, has now clearly occurred. Both Aurelius and AMA bear an affirmative obligation to ensure that all potentially relevant materials are identified, secured, and maintained in their current form. Failure to comply with this preservation obligation may result in severe legal consequences. Under Federal Rule of Civil Procedure 37(e), a court may order measures up to and including adverse inference instructions, evidentiary sanctions, monetary penalties, or default judgment if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the lost information cannot be restored or replaced through additional discovery. Courts have imposed similar sanctions for the destruction of hard copy documents and other tangible materials. Aurelius's and AMA's credibility before the court may be irreparably damaged by any failure to preserve relevant evidence.
This notice is intended to ensure that Aurelius and AMA take all reasonable steps to comply with their legal obligations. We ask that you treat this matter with the utmost urgency and seriousness.
II. Background Summary
To provide context for the scope of the preservation obligation, we summarize below the factual background giving rise to the anticipated litigation.
Aurelius Global Media Group PLC is a United Kingdom–based media conglomerate that owns an extensive library of copyrighted audiovisual content. Aurelius's content library encompasses over 4,200 film and television titles, including some of the most commercially successful and critically acclaimed properties in contemporary entertainment. Among the crown jewels of this library are the "Meridian" franchise, consisting of six feature films with a combined global box office of approximately $1.43 billion; the "Iron Compass" series, a critically acclaimed four-season, 48-episode drama that averaged 9.2 million UK viewers per episode during its original broadcast run; and the "Thornfield" period drama catalog, which includes 12 titles and has been honored with 7 BAFTA awards.
Through its ongoing content monitoring and digital rights enforcement efforts, Aurelius has identified that StreamNow Holdings, Inc. — a Delaware corporation (File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010 — has, without authorization from Aurelius or any authorized representative of Aurelius, reproduced, distributed, and publicly performed at least 217 Aurelius-owned audiovisual works through its proprietary streaming platform and sublicensed distribution channels. The 217 works at issue consist of 142 feature films and 75 television series comprising a total of 1,038 individual episodes. The unauthorized exploitation occurred over an approximately 22-month period, from on or about April 1, 2024, through at least January 31, 2026, and may be continuing.
StreamNow claims to have obtained distribution rights to the Aurelius titles through a purported Content Distribution Agreement dated March 15, 2024, entered into with Meridian Digital Distributors, LLC (California Secretary of State File No. 202115729430). MDD is a company owned and operated by Franklin Ogilvie, a former mid-level licensing manager at Aurelius Media Americas, Inc. Ogilvie's employment with AMA terminated on June 30, 2021, following an internal investigation into his unauthorized access to Aurelius's content management systems and misuse of proprietary information. Ogilvie's separation agreement, executed on June 30, 2021, contains express non-compete, non-solicitation, and intellectual property usage prohibitions.
Aurelius's records confirm unequivocally that it has never granted MDD, Franklin Ogilvie, or any entity controlled by or affiliated with Ogilvie any license, sublicense, distribution authority, or other right of any kind with respect to any Aurelius-owned content. The purported Content Distribution Agreement between MDD and StreamNow is therefore without any legitimate basis, and the distribution of Aurelius content thereunder constitutes willful copyright infringement.
The scope of the infringement is not limited to StreamNow's own platform. Our investigation has revealed that StreamNow also sublicensed content bundles containing Aurelius titles to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators: (1) Brindoval Channel Networks, Inc. (Dallas, Texas); (2) BrightLoop Media, LLC (Miami, Florida); (3) Velvet Stream Partners, LP (Toronto, Ontario, Canada); and (4) Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia). The unauthorized distribution through these additional channels has compounded the harm to Aurelius and broadened the geographic scope of the infringement.
Based on publicly available financial data, industry estimates, and preliminary analysis by Aurelius's finance team, the estimated revenue attributable to StreamNow's unauthorized exploitation of Aurelius-owned content during the infringement period is approximately $38.6 million. This figure does not account for additional revenue earned by the four FAST channel operators or the broader market harm to Aurelius's licensing program.
The infringement was first discovered by Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, on October 15, 2025, during routine content monitoring operations. Ms. Kowalski escalated the matter to Fiona Hartwell, General Counsel, on October 22, 2025. An internal investigation was commenced at that time, initially in coordination with Bexley Marsh Solicitors LLP, Aurelius's UK outside counsel, who were engaged on November 18, 2025. On November 3, 2025, during the investigation, Sandra Yee, StreamNow's Vice President of Content Acquisition, sent an email to Raj Anantharam, Aurelius's SVP of Content Licensing & Distribution, claiming that MDD possessed valid sublicense authority. This communication is inconsistent with Aurelius's records and is a critical piece of evidence in the anticipated litigation.
III. Scope of Preservation Obligation
The preservation obligation set forth in this notice is intentionally broad in order to ensure that all potentially relevant materials are captured and preserved. The scope of the hold is defined by reference to the persons and entities covered, the applicable time period, and the subject matter categories described below.
A. Persons and Entities Covered
This litigation hold applies to Aurelius Global Media Group PLC (Companies House Registration No. 08724561) and all of its subsidiaries and affiliates, including specifically and without limitation Aurelius Media Americas, Inc. (a Delaware corporation). The hold extends to all officers, directors, employees, contractors, consultants, temporary workers, interns, and agents of Aurelius and AMA who may possess, have access to, or have custody or control over documents or ESI that fall within the scope of this hold. This includes individuals at all levels of the organization, regardless of title, department, or geographic location.
Key custodians who must be notified immediately and who bear heightened preservation responsibilities are identified in Section VII below. However, the preservation obligation is not limited to those specific individuals. Any person within the Aurelius organization who becomes aware that he or she possesses relevant materials must take immediate steps to preserve those materials and notify the designated litigation hold coordinator.
B. Time Period
All documents and ESI created, sent, received, modified, or stored from January 1, 2016, through the present date and continuing must be preserved. The hold will remain in effect on a continuing, forward-looking basis until it is formally released in writing by Calderwood & Harkness LLP.
This time period has been selected to encompass, with appropriate margins, the following critical phases of the factual narrative:
• Franklin Ogilvie's employment at Aurelius Media Americas, Inc. (approximately 2017 through June 30, 2021);
• The internal investigation leading to Ogilvie's separation from AMA (2021);
• The formation of Meridian Digital Distributors, LLC (late 2021);
• The execution of the purported Content Distribution Agreement between MDD and StreamNow (March 15, 2024);
• The full infringement period during which Aurelius content was unauthorized streamed and sublicensed (April 1, 2024, through January 31, 2026);
• The discovery of the unauthorized streaming by Lena Kowalski (October 15, 2025);
• The escalation to Fiona Hartwell and commencement of the internal investigation (October 22, 2025);
• The engagement of Bexley Marsh Solicitors LLP (November 18, 2025); and
• All subsequent investigation, remediation, and litigation preparation activity through the present and continuing.
The January 1, 2016, start date also captures any pre-employment background or communications relating to Ogilvie that may predate the commencement of his employment, as well as any historical licensing and distribution records for the 217 titles that may be relevant to establishing ownership, chain of title, and fair market value.
C. Subject Matter Categories
Documents and ESI must be preserved if they relate to any of the following subject matter categories. These categories should be construed broadly, and any doubt as to whether a particular document or item of ESI falls within the scope of the hold should be resolved in favor of preservation.
1. The 217 Works at Issue. All documents relating to the creation, production, acquisition, ownership, copyright registration, licensing, distribution, and exploitation of each of the 217 audiovisual titles identified in the enclosed List of 217 Titles Subject to Litigation Hold. This includes, without limitation, all documents specifically relating to the Meridian franchise (six feature films), the Iron Compass series (four seasons, 48 episodes), and the Thornfield period drama catalog (12 titles). This category encompasses production agreements, chain-of-title documents, work-for-hire agreements, assignment agreements, acquisition agreements, co-production agreements, and any other documentation establishing or affecting Aurelius's ownership interest in the works.
2. Copyright Registrations. All U.S. Copyright Office registration certificates, applications, correspondence with the Copyright Office, recordation documents, and chain-of-title documentation for each of the 217 titles at issue. This includes the 189 titles for which timely copyright registrations were filed prior to the commencement of infringement, as well as the 28 titles for which registrations postdate the commencement of infringement. All supporting documentation submitted in connection with such registrations must also be preserved.
3. StreamNow Holdings, Inc. All communications, correspondence, documents, agreements, memoranda, and ESI of any kind that relate to, reference, or mention StreamNow Holdings, Inc., or any of the following individuals in their capacity as StreamNow officers, employees, agents, or representatives: Derek Calloway (Chief Executive Officer), Priya Menon (Chief Operating Officer), Tobias Rennert (General Counsel), Sandra Yee (Vice President, Content Acquisition), and any other StreamNow employee, agent, or representative with whom any Aurelius or AMA personnel have communicated. This includes, without limitation, the November 3, 2025, email from Sandra Yee to Raj Anantharam and any response thereto.
4. Meridian Digital Distributors, LLC. All communications, documents, agreements, and ESI relating to or referencing Meridian Digital Distributors, LLC, including any purported license, sublicense, distribution agreement, content supply agreement, or other arrangement of any kind, whether executed or merely proposed, between MDD and any party. This also includes any documents reflecting Aurelius's or AMA's awareness of or investigation into MDD's activities.
5. Franklin Ogilvie. All personnel records, employment agreements (including any offer letters, employment contracts, and amendments), the separation agreement dated June 30, 2021 (including all exhibits and attachments, specifically including the non-compete, non-solicitation, and intellectual property usage prohibitions contained therein), performance reviews, internal investigation files, disciplinary records, warnings, and any other HR records relating to Ogilvie. This category also includes all access logs documenting Ogilvie's use of Aurelius's content management systems, digital asset management platforms, and other internal systems during and after his employment. Any post-separation communications with, about, or referencing Ogilvie must also be preserved, including any communications between Aurelius/AMA personnel and Ogilvie, or any third-party communications referencing Ogilvie's activities after his departure.
6. Authorized Licensing and Distribution. All existing and historical license agreements, distribution agreements, content supply agreements, output deals, and other agreements pursuant to which Aurelius has authorized the exploitation of any of the 217 titles at issue, regardless of the platform, territory, or medium. This includes comparable arm's-length license agreements for the same or similar titles that may be used for fair market value benchmarking in connection with damages calculations. Revenue reports, minimum guarantees, and royalty accounting under such agreements must also be preserved.
7. Internal Investigation (2021). All documents relating to the internal investigation of Franklin Ogilvie's unauthorized access to and misuse of Aurelius's content management systems conducted in 2021, including without limitation investigation reports, memoranda, forensic analysis reports, interview notes, witness statements, email reviews, system access audits, and any communications with Bexley Marsh Solicitors LLP (Aurelius's UK outside counsel) relating to the investigation and Ogilvie's separation. Any documents reflecting remedial measures taken by Aurelius or AMA following the investigation must also be preserved.
8. Discovery of Infringement and Subsequent Investigation. All documents and communications from October 15, 2025, onward relating to Lena Kowalski's discovery of Aurelius titles on the StreamNow platform, the escalation of the matter to Fiona Hartwell on October 22, 2025, the commencement and progress of the internal investigation, any informal or formal communications with StreamNow (including the November 3, 2025, email from Sandra Yee asserting MDD sublicense authority), the engagement of Bexley Marsh Solicitors LLP on November 18, 2025, and the subsequent engagement of Calderwood & Harkness LLP on February 12, 2026. All investigation reports, forensic analyses, content audits, and memoranda generated during the investigation must be preserved.
9. Revenue and Financial Data. All financial records, revenue reports, royalty statements, sales reports, accounting records, internal financial projections, budgets, and financial analyses relating to revenue generated from the 217 titles at issue during the relevant period (January 1, 2016, through the present). This includes licensing revenue received by Aurelius from authorized distributors, viewership and audience data for the 217 titles, advertising revenue data, and any evidence of revenue displacement, lost licensing opportunities, market harm, or diminution of the value of Aurelius's content library attributable to the unauthorized exploitation. Any internal analyses estimating the $38.6 million in revenue attributable to StreamNow's unauthorized exploitation must also be preserved.
10. FAST Channel Operators. All documents, communications, and ESI relating to Brindoval Channel Networks, Inc. (Dallas, Texas), BrightLoop Media, LLC (Miami, Florida), Velvet Stream Partners, LP (Toronto, Ontario, Canada), and Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia), including any communications regarding the sublicensing of Aurelius content to or through these entities, any license agreements or content supply agreements between StreamNow and these entities, and any information regarding the exploitation of Aurelius titles by these entities.
11. Insurance. All documents relating to the Fortbridge Specialty Insurance Company media liability and IP enforcement insurance policy (Policy No. FSI-ML-2024-07821), including the policy itself, all endorsements, riders, and amendments, all correspondence with Fortbridge Specialty Insurance Company, all correspondence with Calder & Whitfield Insurance Brokers Ltd. (Aurelius's insurance broker), and any claims, notices, or coverage requests submitted or contemplated in connection with the present matter. Premium payment records and renewal correspondence should also be preserved.
IV. Types of Materials to Be Preserved
The preservation obligation extends to all forms of documents and information, regardless of the medium, format, or location in which they are stored. The following categories provide guidance but are not intended to be exhaustive. When in doubt, preserve.
A. Electronically Stored Information (ESI)
ESI constitutes the largest and most critical category of potentially relevant materials. The following types of ESI must be preserved:
(a) Email. All email communications on all email systems used by Aurelius and AMA, including corporate email systems (whether hosted on-premises or in the cloud), archived email, journaled email, personal email accounts (such as personal Northgate Software, Cascade Health IT, Ridgeline Technologies, or other webmail accounts) to the extent they were used for business purposes relating to any of the subject matter categories described above, and any email accounts maintained on behalf of departed employees. All attachments to emails must be preserved along with the parent messages. Calendar entries, meeting invitations, task items, and contact records associated with email systems must also be preserved. Email metadata — including sender, recipient, date/time stamps, routing information, read receipts, and folder locations — must be preserved in its native form.
(b) Content Management System ("CMS") Records. All records maintained in Aurelius's and AMA's content management systems, digital asset management platforms, and media asset management systems, including all logs, access records, upload and download records, check-in/check-out records, version histories, metadata, rights management data, and any other data fields associated with the 217 titles at issue. Access control lists, user permission records, and audit trails for CMS systems must be preserved to establish who had access to Aurelius content and what actions were taken with respect to that content.
(c) Licensing Databases. All entries, records, amendments, notes, and audit trails in Aurelius's and AMA's licensing databases, rights management systems, and deal-tracking systems relating to the 217 titles at issue and any relationship — actual, purported, or attempted — with MDD, StreamNow, Franklin Ogilvie, or any of the FAST channel operators identified above.
(d) Internal Messaging Platforms. All communications on internal messaging and collaboration platforms, including without limitation Meridian Solutions, Northgate Data Systems, Meridian Services Inc. (to the extent used for business purposes), signal (to the extent used for business purposes), and any other instant messaging, group chat, or internal communication tools used by Aurelius or AMA personnel.
(e) Shared Drives and Cloud Storage. All documents, files, presentations, spreadsheets, databases, and other materials stored on shared network drives, cloud storage platforms (including Aldermere Systems, Cobalt Ridge Systems, Hollowell Health IT, Larkspur Technologies, box, and similar services), document management systems, and local workstations of key custodians.
(f) Backup Tapes and Disaster Recovery Archives. All backup tapes, disaster recovery archives, and other backup media that may contain relevant data from the preservation period (January 1, 2016, through the present). Backup tapes must not be recycled, overwritten, or destroyed. If backup tapes are subject to rotation schedules that would result in overwriting, those schedules must be immediately suspended for tapes containing data within the scope of this hold.
(g) Website and Intranet Content. All website content, intranet pages, portal content, and online publications referencing the 217 titles at issue or any of the parties identified in this notice.
(h) Mobile Device Data. All data residing on mobile devices (smartphones, tablets, and similar devices) of key custodians, including text messages (SMS and MMS), voicemails, data from messaging applications (including Meridian Services Inc., Signal, Westmark Software, Kestrel Data Systems, and similar applications), call logs, photographs, videos, and notes. Where key custodians use personal mobile devices for business purposes, those devices are subject to this hold to the extent they contain business-related communications within the scope of this notice.
B. Hard Copy Documents
In addition to ESI, all hard copy documents potentially relevant to this matter must be preserved, including without limitation:
(a) Paper files, memoranda, handwritten notes, correspondence, contracts, executed agreements, and printed materials of any kind relating to the subject matter categories described in Section III.C above.
(b) Personnel files and human resources records for Franklin Ogilvie, including his complete employment file maintained by AMA and any records maintained by Aurelius's London headquarters.
(c) Board of directors minutes, executive committee minutes, audit committee minutes, and any other corporate governance records that reference or relate to any of the subject matter categories described above, including any board-level discussions of the StreamNow infringement, the Ogilvie internal investigation, or the licensing and distribution of the 217 titles.
(d) Any physical correspondence or written communications received from or sent to StreamNow, MDD, Franklin Ogilvie, or any of the FAST channel operators.
C. Audio/Visual Materials
(a) Recordings of meetings, presentations, conferences, interviews, or other events relevant to the subject matter categories described above, whether in audio, video, or combined format, and regardless of the recording medium.
(b) Copies of the 217 audiovisual works at issue in all formats maintained by Aurelius or AMA, including master copies, distribution copies, screening copies, and promotional materials. All versions, edits, and formats must be preserved.
V. Prohibition on Destruction, Alteration, or Concealment
Effective immediately upon receipt of this notice, Aurelius and AMA must suspend all routine document destruction, recycling, and deletion policies as they pertain to any documents or ESI within the scope of this litigation hold. This suspension applies to all document retention and destruction schedules, records management policies, clean-desk policies, and any other policies or practices that could result in the destruction, deletion, overwriting, or loss of relevant materials.
No documents or ESI within the scope of this hold may be destroyed, deleted, overwritten, modified, altered, moved, relocated, concealed, or otherwise disposed of, whether in the ordinary course of business or otherwise. This prohibition applies regardless of whether the destruction or alteration would occur as part of routine business operations, IT maintenance, system upgrades, office moves, personnel transitions, or any other activity.
Auto-delete policies on email systems, messaging platforms, collaboration tools, backup systems, and any other data repositories must be immediately suspended for all key custodians identified in Section VII and for any systems or repositories containing potentially relevant data. This includes, without limitation, auto-archiving and auto-deletion settings in Strathmore Data Systems, Ashgrove Software, Crestline Software, Meridian Solutions, Northgate Data Systems, and any other platforms in use by Aurelius or AMA.
The Information Technology departments at both Aurelius (London) and AMA (Los Angeles) must be immediately instructed to implement technical measures to prevent the automated deletion, overwriting, or modification of any data within the scope of this hold. This includes placing legal holds on relevant mailboxes, suspending backup tape rotation schedules, disabling auto-deletion settings, and implementing any other technical safeguards necessary to ensure preservation.
Any employee, contractor, or agent who becomes aware of the actual or threatened destruction, alteration, or loss of materials within the scope of this hold must immediately report the situation to Fiona Hartwell, the designated litigation hold coordinator, and Calderwood & Harkness LLP.
VI. IT Coordination
The effective implementation of this litigation hold requires close coordination between Aurelius's and AMA's IT departments and outside counsel. Accordingly, the IT departments at Aurelius (London) and AMA (Los Angeles) should be directed to take the following actions immediately:
(a) Identify and Preserve Backup Tapes and Archives. Identify all backup tapes, disaster recovery archives, and other backup media containing data from January 1, 2016, through the present. All such media must be sequestered and preserved. No backup tapes containing data within the preservation period may be recycled, overwritten, or destroyed.
(b) Suspend Auto-Deletion and Data Retention Cycling. Suspend all automatic deletion settings, data retention cycling policies, and scheduled purges for all identified key custodians and all data repositories that may contain relevant information. This includes but is not limited to email systems, collaboration platforms, shared drives, cloud storage, CMS platforms, licensing databases, and backup systems.
(c) Preserve CMS Access Logs and Audit Trails. Preserve all content management system access logs and audit trails in their native format, with full metadata intact. These logs are essential to establishing the chain of events surrounding Ogilvie's access to Aurelius content and the unauthorized distribution of that content. No access logs should be purged, truncated, or modified.
(d) Forensic Imaging. Image or create forensic copies of relevant workstations, laptops, mobile devices, and server directories as directed by counsel. Forensic images should be created using industry-standard forensic tools and procedures to ensure the integrity and admissibility of the data. Chain of custody documentation must be maintained for all forensic images.
(e) Coordination with CipherTrace Analytics, LLC. Coordinate with Calderwood & Harkness LLP and, as necessary, with CipherTrace Analytics, LLC, Calderwood & Harkness's retained digital forensics expert, for any required forensic preservation, data extraction, or analysis. CipherTrace Analytics is led by Dr. Nathan Frey and is located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. Dr. Frey and his team may need direct access to Aurelius and AMA systems and personnel to conduct forensic preservation work. All such access will be coordinated through Calderwood & Harkness and the designated litigation hold coordinator.
Calderwood & Harkness will schedule a technical coordination call with Aurelius's and AMA's IT leadership within one week of the date of this notice to discuss the specific technical steps required for implementation.
VII. Key Custodians — Immediate Notification Required
The following individuals have been identified as key custodians who are likely to possess documents and ESI within the scope of this litigation hold. Each of these individuals must be notified of the hold immediately and must receive either a copy of this notice or a custodian-specific preservation instruction:
1. Fiona Hartwell — General Counsel, Aurelius Global Media Group PLC. Ms. Hartwell is the recipient of this notice and bears primary responsibility for implementing the litigation hold across the entire Aurelius organization. Ms. Hartwell's own files, communications, and records relating to the StreamNow matter, the Ogilvie investigation, and content licensing are within the scope of the hold.
2. Lena Kowalski — Head of Digital Rights Enforcement, Aurelius Global Media Group PLC. Ms. Kowalski discovered the unauthorized streaming of Aurelius content on the StreamNow platform on October 15, 2025, and is a central witness in the anticipated litigation. All of her files, communications, monitoring reports, investigation notes, and related materials must be preserved.
3. Raj Anantharam — Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC. Mr. Anantharam is the business-side content lead responsible for licensing and distribution of Aurelius titles and is the recipient of the November 3, 2025, email from Sandra Yee at StreamNow. All of his files, communications, licensing records, and related materials must be preserved.
4. Sir Alistair Pemberton — Chief Executive Officer, Aurelius Global Media Group PLC. To the extent Sir Alistair possesses any communications, memoranda, board presentations, or other materials relating to the StreamNow infringement, the Ogilvie investigation, or the licensing and distribution of the 217 titles at issue, all such materials must be preserved.
5. Additional Custodians. Any current or former employees of Aurelius or AMA who had involvement in any of the following matters must also be identified and notified:
(a) The internal investigation of Franklin Ogilvie in 2021;
(b) Ogilvie's employment, supervision, management, or separation from AMA;
(c) The licensing, distribution, or exploitation of any of the 217 titles at issue; or
(d) The discovery, investigation, and remediation of the StreamNow infringement from October 15, 2025, onward.
6. Heads of Information Technology at Aurelius (London) and AMA (Los Angeles), who must implement the technical preservation measures described in Sections V and VI above.
All custodians should receive a copy of this litigation hold notice or a custodian-specific preservation instruction tailored to their role. Each custodian must acknowledge receipt in writing by signing and returning the enclosed Custodian Acknowledgment Form. Completed acknowledgment forms should be returned to Fiona Hartwell and forwarded to Calderwood & Harkness for our records.
We request that Aurelius provide Calderwood & Harkness with a complete list of all notified custodians, together with their titles, departments, and contact information, within ten (10) business days of the date of this notice.
VIII. Acknowledgment and Compliance
Fiona Hartwell, on behalf of Aurelius Global Media Group PLC and Aurelius Media Americas, Inc., is requested to acknowledge receipt of this litigation hold notice in writing (by email or letter addressed to Marcus Delgado at the Calderwood & Harkness Los Angeles office) within five (5) business days of the date of this notice — that is, no later than February 21, 2026. The acknowledgment should confirm that Aurelius and AMA understand the scope and requirements of the hold, that the hold has been communicated to the relevant personnel, and that steps are being taken to implement the hold.
Aurelius should designate a litigation hold coordinator — an internal point of contact — to oversee day-to-day compliance with the hold and to serve as the primary liaison between Aurelius/AMA and Calderwood & Harkness on all preservation matters. We recommend that this individual be someone with sufficient organizational authority to direct compliance across departments and geographies, and with the technical understanding necessary to coordinate with IT on implementation. We are happy to discuss appropriate candidates for this role at your convenience.
Calderwood & Harkness will issue periodic reminders of this litigation hold to ensure ongoing compliance. As the matter develops, we may supplement, expand, or narrow the scope of this hold in writing. No changes to the scope of the hold will be effective unless communicated in writing by Calderwood & Harkness.
Any questions regarding the scope, interpretation, or implementation of this litigation hold should be directed to:
Marcus Delgado, Partner, intellectual Property Litigation Telephone: (310) 557-4218
Email: m.delgado@calderwoodharkness.com
Wendy Schultz, Senior Associate, intellectual Property Litigation Telephone: (310) 557-4235
Email: w.schultz@calderwoodharkness.com
Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
IX. Duration of Hold
This litigation hold remains in effect until further written notice from Calderwood & Harkness LLP. No individual within Aurelius or AMA has the authority to release, modify, or narrow this hold without written authorization from Calderwood & Harkness.
The hold will not be released until the matter described herein is fully and finally resolved, whether by settlement, final judgment (including exhaustion of all appellate rights), voluntary dismissal, or mutual written agreement of the parties, and Calderwood & Harkness provides a formal written release of the hold. Until such a release is issued, all preservation obligations described in this notice remain in full force and effect.
Aurelius and AMA should anticipate that this hold will remain in effect for a substantial period of time, potentially several years, given the complexity of the anticipated litigation and the number of parties and works involved.
X. Consequences of Non-Compliance
We wish to emphasize in the strongest possible terms the seriousness of the preservation obligations described in this notice. Failure to comply with this litigation hold may expose Aurelius and AMA to severe legal consequences, including but not limited to:
• Court-imposed sanctions, including monetary penalties assessed against the company and, in appropriate cases, against individual officers and employees;
• Adverse inference instructions, in which the court instructs the jury that it may presume destroyed evidence was unfavorable to Aurelius — an instruction that can be devastating to the prosecution of Aurelius's claims;
• Preclusion of evidence, in which the court bars Aurelius from introducing evidence on topics for which relevant materials were destroyed;
• Dismissal of claims, in the most extreme cases of willful or bad faith spoliation; and
• Referral for contempt proceedings or other judicial action.
Under Federal Rule of Civil Procedure 37(e), if ESI that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and the lost information cannot be restored or replaced through additional discovery, the court may: (1) upon finding prejudice to another party from the loss of the information, order measures no greater than necessary to cure the prejudice; or (2) only upon finding that the party acted with the intent to deprive another party of the information's use in the litigation, presume that the lost information was unfavorable to the party, instruct the jury that it may or must presume the information was unfavorable, or dismiss the action or enter a default judgment.
Courts have consistently held that the duty to preserve arises when litigation is reasonably anticipated, and that a party's failure to issue a timely litigation hold or to take affirmative steps to prevent the destruction of relevant evidence may itself constitute evidence of bad faith or willful spoliation. See, e.g., Zubulake v. Ashgrove Trust Bank, 220 F.R.D. 212 (S.D.N.Y. 2003); Rimkus Consulting Group, Inc. v. Cammarata, 688 F. Supp. 2d 598 (S.D. Tex. 2010).
All personnel who receive this notice or a custodian-specific preservation instruction must understand the seriousness of this obligation and must take immediate, affirmative steps to ensure compliance. Ignorance of the hold is not a defense to a finding of spoliation if reasonable steps to communicate and implement the hold were not taken.
Closing
Calderwood & Harkness LLP is fully available to assist Aurelius and AMA with the implementation of this litigation hold. Our assistance includes, but is not limited to, providing guidance and training to IT staff on technical preservation measures, conducting custodian interviews to identify the location and nature of potentially relevant materials, advising on the scope of the hold as applied to specific custodians or data sources, and coordinating with CipherTrace Analytics, LLC for forensic preservation and data extraction as needed.
We are grateful for Aurelius's prompt attention to this matter and appreciate the seriousness with which your organization is approaching its preservation obligations. The early and thorough implementation of this hold will serve Aurelius's interests well in the anticipated litigation and will position the company to present its strongest possible case.
Please do not hesitate to contact Marcus Delgado or Wendy Schultz at the Calderwood & Harkness Los Angeles office with any questions, concerns, or requests for further guidance.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Marcus Delgado Partner, intellectual Property Litigation Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 557-4218 Facsimile: (310) 557-4201
Email: m.delgado@calderwoodharkness.com
cc: (via email)
Catherine Bloom, Partner, Calderwood & Harkness LLP Wendy Schultz, Senior Associate, Calderwood & Harkness LLP Omar Siddiqui, Associate, Calderwood & Harkness LLP
Enclosures:
1. List of 217 Titles Subject to Litigation Hold — Copyright Registration Summary Report compiled from Lexington IP Services data, completed January 22, 2026. This report identifies each of the 217 audiovisual works by title, format (feature film or television series), number of episodes (where applicable), U.S. Copyright Office registration number, registration date, and registration status (timely or post-infringement).
2. Custodian Acknowledgment Form — Template for each custodian to sign confirming receipt of this litigation hold notice (or a custodian-specific preservation instruction) and acknowledging their understanding of their preservation obligations. Completed forms should be returned to Fiona Hartwell and forwarded to Calderwood & Harkness LLP.

CALDERWOOD & HARKNESS LLP Attorneys at Law

VIA EMAIL AND OVERNIGHT COURIER

CALDERWOOD & HARKNESS LLP

Record

Parties

Dates

Amounts