1017-00003 · Aurelius Global Media Group · Factual Investigation

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CALDERWOOD & HARKNESS LLP

Intellectual Property Group

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

ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL This memorandum constitutes attorney work product prepared in anticipation of litigation and is protected by the attorney-client privilege and work product doctrine. Distribution is restricted to the engagement team and client representatives authorized to receive privileged communications. Any unauthorized review, use, disclosure, or distribution is strictly prohibited.

MEMORANDUM

TO: Wendy Schultz, Senior Associate; Marcus Delgado, Partner

FROM: Omar Siddiqui, Associate

DATE: March 5, 2026

RE: Summary of CipherTrace Analytics, LLC Forensic Analysis — StreamNow Holdings, Inc. Platform

CLIENT: Aurelius Global Media Group PLC

MATTER NO.: 1017-00003

I. PURPOSE AND SCOPE OF THIS SUMMARY

This memorandum summarizes the technical and forensic findings of CipherTrace Analytics, LLC ("CipherTrace"), retained by Calderwood & Harkness LLP on behalf of Aurelius Global Media Group PLC ("Aurelius" or "AGMG") pursuant to the expert retention letter dated February 18, 2026. CipherTrace was engaged to perform a comprehensive digital forensic analysis of the StreamNow Holdings, Inc. ("StreamNow") streaming platform to evaluate and document the unauthorized presence, distribution, and monetization of Aurelius-owned audiovisual works on that platform.

Specifically, CipherTrace was engaged to accomplish four primary objectives:

(a) confirm the presence of Aurelius-owned audiovisual works on the StreamNow platform through proprietary audio-visual content fingerprinting technology;

(b) extract and analyze platform metadata regarding dates of content ingestion, content classification, tier assignment, and geographic availability of Aurelius titles within the StreamNow ecosystem;

(c) analyze viewership and traffic data attributable to Aurelius titles, including total stream counts, unique viewer counts, and aggregate viewing hours over the relevant period; and

(d) model revenue attribution across StreamNow's subscription (SVOD), advertising-supported (AVOD), and sublicensing revenue streams, quantifying the economic value StreamNow derived from the unauthorized exploitation of Aurelius's content catalog.

The analysis was conducted under the supervision and direction of Dr. Nathan Frey, Director of Digital Media Forensics at CipherTrace Analytics, LLC, located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. Dr. Frey served as the engagement lead and is prepared to serve as the firm's testifying expert in connection with this matter.

The forensic analysis covers the twenty-two-month infringement period from approximately April 1, 2024 through January 31, 2026 (the "Infringement Period"), during which time all 217 Aurelius-owned audiovisual titles were present and available for streaming on the StreamNow platform without authorization from Aurelius or any entity lawfully empowered to grant such rights.

This summary has been prepared for use by the engagement team in connection with pre-suit demand proceedings directed to StreamNow Holdings, Inc. and its principals, and to support anticipated litigation in the United States District Court for the Central District of California. The findings documented herein are based on CipherTrace's preliminary findings report, which was delivered to Calderwood & Harkness on March 3, 2026, together with supporting data sets and exhibits furnished under the terms of the expert retention letter.

II. CIPHERTRACE ANALYTICS — QUALIFICATIONS AND METHODOLOGY OVERVIEW

A. Firm Background and Expert Qualifications

CipherTrace Analytics, LLC is a Delaware limited liability company headquartered at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. The firm specializes in digital media forensics, content identification and verification, and revenue attribution analysis for entertainment and technology-related litigation. CipherTrace has been retained as a forensic expert in matters involving major motion picture studios, television production companies, music publishers, and digital platform operators across a range of intellectual property disputes. The firm maintains state-of-the-art forensic laboratories and computing infrastructure designed to handle large-scale content fingerprinting and metadata analysis.

The CipherTrace engagement team for this matter was led by Dr. Nathan Frey, Director of Digital Media Forensics. Dr. Frey holds a Ph.D. in Computer Science from Stanford University, with a specialization in audio-visual fingerprinting and digital watermarking technologies. He has over fifteen years of professional experience in content protection forensics, and has served as a testifying expert in more than thirty federal copyright infringement cases in U.S. District Courts across multiple circuits. His expert testimony has been admitted without challenge under the Daubert standard, and his published research on audio-visual fingerprinting methodologies has been cited by peer-reviewed journals and federal courts alike. Dr. Frey's curriculum vitae is maintained on file and will be included as an appendix to his formal expert report.

The engagement was further supported by a team of six senior analysts with specialized expertise in metadata extraction from digital streaming platforms, streaming platform architecture and content delivery network analysis, and econometric modeling of digital media revenues. The combined expertise of the CipherTrace engagement team ensures that the findings presented herein reflect the application of best-in-class forensic techniques and industry-standard analytical methods.

B. Methodology Summary

CipherTrace employed a multi-phase forensic methodology encompassing content fingerprinting, metadata extraction, viewership analysis, and revenue attribution modeling. Each phase is summarized below.

Content Fingerprinting. CipherTrace deployed its proprietary audio-visual fingerprinting technology, designated as the CT-AVF Engine v.4.2, to compare reference copies of the 217 Aurelius-owned audiovisual titles against content available on the StreamNow platform. The 217 titles comprise 142 feature films and 75 television series, the latter encompassing a total of 1,038 individual episodes. Reference materials — consisting of digital masters and authorized distribution copies — were provided by Aurelius Media Americas, Inc., located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067, through its Head of Digital Rights Enforcement, Lena Kowalski. The CT-AVF Engine employs a dual-modality matching approach that analyzes both audio waveform signatures and visual frame composition to generate a composite confidence score for each content match. This dual-modality approach significantly reduces the risk of false positives and ensures that matches are accurate and defensible.

Metadata Extraction. CipherTrace extracted platform metadata from the StreamNow platform, including content identifiers (both internal and external-facing), ingestion timestamps, content classification tags (genre, rating, language), geographic distribution flags, and tier availability indicators (subscription tier versus advertising-supported tier). Metadata was obtained through analysis of publicly accessible StreamNow platform interfaces, publicly available application programming interface ("API") endpoints, and structured data embedded in the platform's content delivery architecture. All extracted metadata was preserved in forensically sound format with appropriate chain-of-custody documentation.

Viewership and Traffic Analysis. CipherTrace analyzed publicly available viewership metrics published by StreamNow, third-party audience measurement data from recognized industry measurement services, and platform engagement indicators (including trending lists, editorial features, and recommendation algorithm outputs) to estimate total streams, unique viewer counts, and aggregate viewing hours attributable to Aurelius titles during the Infringement Period. Where StreamNow's proprietary viewership data was not publicly available, CipherTrace employed validated estimation methodologies consistent with accepted industry practices for digital streaming audience measurement.

Revenue Attribution Modeling. CipherTrace developed a multi-factor econometric model to attribute StreamNow's revenues to the Aurelius content catalog across three distinct revenue streams: subscription revenue (SVOD), advertising revenue (AVOD), and sublicensing fees received from third-party FAST (Free Ad-Supported Streaming Television) channel operators. The revenue attribution model incorporates viewership share analysis, premium-tier weighting adjustments to account for the disproportionate presence of Aurelius titles in higher-value subscription tiers, advertising CPM (cost per thousand impressions) data derived from industry benchmarks, and sublicensing fee allocation based on the proportional representation of Aurelius content within sublicensed content bundles. The model was developed in consultation with Calderwood & Harkness and with reference to preliminary data inputs from Hargrove Economic Consulting Group, LLC, under the direction of Dr. Elena Vasquez.

Data Collection Period. Forensic data collection was conducted between February 18, 2026 and March 1, 2026. The analysis encompasses historical data spanning the full Infringement Period from April 1, 2024 through January 31, 2026.

Quality Controls. All findings presented in this summary and in CipherTrace's preliminary findings report have been subjected to internal peer review within CipherTrace Analytics. Chain-of-custody documentation has been maintained for all reference materials received from Aurelius Media Americas, Inc. and for all data sets extracted during the forensic analysis. The integrity of the forensic process is documented in Exhibit H and will be fully described in Dr. Frey's formal expert report.

III. CONTENT FINGERPRINTING RESULTS — CONFIRMATION OF INFRINGING TITLES

A. Overview of Findings

CipherTrace's CT-AVF Engine v.4.2 confirmed the presence of all 217 Aurelius-owned audiovisual titles on the StreamNow platform during the Infringement Period. The confirmed titles consist of 142 feature films and 75 television series, with the television series comprising a total of 1,038 individual episodes. The fingerprinting analysis was performed against reference copies of each title provided by Aurelius Media Americas, Inc. and yielded a match confidence level of 99.7% or higher for every one of the 217 titles, based on the CT-AVF Engine's combined audio waveform and visual frame matching methodology. No Aurelius title returned a match confidence score below 99.7%, and the vast majority of titles matched at 99.9% confidence or above. These confidence levels are well within the threshold for forensic certainty as recognized in peer-reviewed literature on audio-visual content identification.

The complete list of all 217 confirmed titles, together with their individual fingerprint match confidence scores, ingestion dates, and tier availability designations, is set forth in Exhibit A to this memorandum.

B. Key Franchise Identification

Among the 217 confirmed titles, several high-profile Aurelius franchise properties warrant particular attention due to their commercial significance, brand value, and outsized contribution to StreamNow's viewership and revenue metrics.

"Meridian" Franchise. All six films in the "Meridian" franchise were confirmed present on the StreamNow platform. The "Meridian" franchise is Aurelius's flagship theatrical film property, with combined global box office receipts of approximately $1.43 billion across six installments. Each of the six films returned a fingerprint match confidence score of 99.9%. The franchise is among the most commercially valuable and widely recognized film properties in Aurelius's catalog, and its unauthorized presence on StreamNow represents a significant portion of the damages at issue.

"Iron Compass" Series. All four seasons of the "Iron Compass" television series, comprising a total of 48 episodes, were confirmed present on the StreamNow platform. "Iron Compass" is Aurelius's highest-rated original television series, averaging approximately 9.2 million UK viewers per episode during its initial broadcast run. The series has won numerous industry awards and maintains a substantial and loyal global audience, making it a highly attractive content asset for any streaming platform.

"Thornfield" Period Drama Catalog. All 12 titles in the "Thornfield" period drama catalog were confirmed present on the StreamNow platform. The "Thornfield" catalog has been recognized with seven British Academy of Film and Television Arts ("BAFTA") awards, establishing it as one of the most critically acclaimed collections of period drama programming in the world.

The remaining confirmed titles consist of 124 additional feature films and 63 additional television series, all of which were confirmed present on the StreamNow platform via fingerprint matching at confidence levels of 99.7% or above. The full details of each title, including individual confidence scores, are presented in Exhibit A.

C. Content Integrity Analysis

CipherTrace's forensic analysis further establishes that the Aurelius titles available on the StreamNow platform were streamed in substantially identical form to the original masters provided by Aurelius Media Americas, Inc. as reference copies. CipherTrace found no evidence of re-encoding, alteration, editing, or transformation that would materially distinguish the copies hosted on StreamNow's platform from Aurelius's authorized versions of the same works. The audio and visual content of the StreamNow copies is, for all forensic purposes, identical to the Aurelius originals.

Additionally, CipherTrace observed that the StreamNow platform displayed Aurelius branding, production credits, and copyright notices on certain titles, further confirming the provenance of the content and establishing that StreamNow was aware — or should have been aware — that the titles originated from Aurelius's catalog. The display of Aurelius branding on the StreamNow platform is documented in screenshots and metadata captures preserved in Exhibit G.

IV. METADATA EXTRACTION — INGESTION DATES AND PLATFORM INTEGRATION

A. Content Ingestion Timeline

CipherTrace's extraction and analysis of StreamNow platform metadata reveals that the 217 Aurelius-owned audiovisual titles were ingested into the StreamNow platform content library beginning on or about April 1, 2024. The ingestion occurred in two distinct phases.

The initial batch ingestion took place over approximately nine days, from approximately March 28, 2024 through April 5, 2024. This initial batch comprised 197 of the 217 Aurelius titles. The timing of this initial batch ingestion corresponds closely to the date of the purported Content Distribution Agreement between Meridian Digital Distributors, LLC ("MDD") and StreamNow Holdings, Inc., which was allegedly executed on March 15, 2024. The proximity between the date of the purported agreement and the commencement of content ingestion suggests that StreamNow began uploading Aurelius titles to its platform promptly upon execution of the agreement with MDD — an entity whose authority to distribute Aurelius content is directly at issue in this matter.

A secondary batch ingestion took place between approximately May 15, 2024 and June 30, 2024, during which the remaining 20 Aurelius titles were added to the StreamNow platform library. These 20 titles appear to have been titles that were either not included in the initial content delivery from MDD or that required additional processing before ingestion.

Critically, all 217 Aurelius titles remained continuously available on the StreamNow platform through at least January 31, 2026, which marks the end of the measured Infringement Period. This constitutes a period of approximately twenty-two months of uninterrupted availability. No titles were removed, taken down, or made unavailable at any point during this period. The content ingestion timeline is illustrated graphically in Exhibit B.

B. Content Classification and Tier Assignment

CipherTrace's metadata extraction further reveals that Aurelius titles were classified within StreamNow's platform architecture under premium content tiers, reflecting StreamNow's recognition of the high commercial value of the Aurelius catalog. Specifically, 183 of the 217 Aurelius titles were made available on the subscription (SVOD) tier, which requires users to maintain a paid subscription to access content. All 217 Aurelius titles were additionally made available on the advertising-supported (AVOD) tier, which permits free access to content with advertising interruptions.

The placement of the majority of Aurelius titles in the SVOD tier is particularly significant because it indicates that StreamNow used Aurelius content as part of its paid subscription value proposition — a function that directly drives subscriber acquisition and retention and generates premium subscription revenues.

Moreover, CipherTrace's analysis of StreamNow's editorial curation metadata confirms that the "Meridian" franchise films and the "Iron Compass" series were featured in StreamNow's curated "Featured" and "Trending" editorial collections. These curated collections are prominently displayed on StreamNow's homepage and within the platform's browsing interface, and are the primary mechanism through which StreamNow drives user attention and engagement toward specific content. The placement of Aurelius titles in these curated collections constitutes active editorial curation by StreamNow — not passive hosting — and demonstrates that StreamNow exercised editorial judgment and control over the presentation and promotion of Aurelius content to its subscribers and viewers.

All Aurelius content was further tagged with StreamNow-generated internal content identifiers, genre classifications, content ratings, and recommendation algorithm metadata. This metadata integration demonstrates that the Aurelius titles were fully incorporated into StreamNow's content management and distribution infrastructure, including its automated recommendation engine, which actively promotes content to users based on viewing history, preferences, and engagement patterns.

C. Geographic Distribution

CipherTrace's metadata analysis confirms that Aurelius titles were made available for streaming across all fourteen countries in which StreamNow operates its platform. These territories include the United States, Canada, Australia, and eleven additional international territories spanning Europe, Latin America, and the Asia-Pacific region. No geographic restrictions or geo-blocking measures were applied specifically to Aurelius content. The titles were distributed globally across StreamNow's entire geographic footprint, maximizing the exposure and reach of the infringing content and amplifying the scope of Aurelius's resulting damages.

The geographic distribution of Aurelius titles across StreamNow's operating territories is illustrated in the geographic distribution map attached as Exhibit C.

V. VIEWERSHIP AND TRAFFIC DATA ANALYSIS

A. Aggregate Viewership Metrics

CipherTrace's analysis of viewership and traffic data attributable to Aurelius titles on the StreamNow platform during the twenty-two-month Infringement Period reveals substantial and sustained audience engagement with the infringing content.

Over the Infringement Period, Aurelius titles generated an estimated total of approximately 84.3 million streams across all territories and platform tiers (SVOD and AVOD combined). This figure encompasses streams of individual feature films and individual television series episodes, counted each time a viewer initiated playback of an Aurelius title.

The estimated number of unique viewer accounts that accessed Aurelius content during the Infringement Period is approximately 12.6 million unique accounts. This figure reflects distinct StreamNow user accounts that streamed at least one Aurelius title during the relevant period and provides an indication of the breadth of the audience that was exposed to Aurelius's content through StreamNow's unauthorized distribution.

Total viewing hours attributable to Aurelius titles during the Infringement Period are estimated at approximately 147 million hours. This aggregate viewing time metric is a key input into the revenue attribution model, particularly for advertising revenue attribution, where viewing duration directly correlates with advertising impression volume and advertising revenue generation.

Detailed monthly viewership data — including stream counts, unique viewer figures, and viewing hours — for each month of the Infringement Period is set forth in Exhibit D.

B. Viewership Share Analysis

To contextualize the viewership data and to support the revenue attribution model, CipherTrace calculated the viewership share of Aurelius titles as a proportion of total StreamNow platform streams during the Infringement Period.

Aurelius titles accounted for approximately 7.18% of total StreamNow streams during the Infringement Period. This viewership share was calculated based on total platform stream counts derived from third-party audience measurement data published by recognized industry measurement services and from StreamNow's own publicly reported engagement metrics, including quarterly and annual disclosures made in connection with investor communications and press releases.

A viewership share of 7.18% is significant for a single content licensor's catalog on a diversified streaming platform, particularly given that StreamNow's platform hosts content from hundreds of content providers. This disproportionate viewership share reflects the premium quality and broad audience appeal of the Aurelius catalog, especially its marquee franchise properties.

Among individual franchise properties, the "Meridian" franchise alone accounted for approximately 1.9% of total platform streams during the Infringement Period, making it one of the single highest-performing content sets on the StreamNow platform. The six "Meridian" films consistently ranked among StreamNow's most-streamed titles in monthly and quarterly performance metrics.

The "Iron Compass" television series contributed approximately 1.4% of total platform streams during the Infringement Period, reflecting the series' strong and loyal audience base and its appeal to the streaming platform's demographic profile.

The remaining Aurelius titles collectively accounted for approximately 3.88% of total platform streams, demonstrating that the value of the Aurelius catalog extends well beyond its marquee franchises and encompasses a deep library of commercially valuable content.

C. Viewership Trends

CipherTrace's temporal analysis of viewership patterns reveals that viewership of Aurelius content remained consistently high throughout the twenty-two-month Infringement Period. There was no significant decline in viewership over time, indicating sustained audience demand for Aurelius titles and ongoing platform-driven promotion of the content.

Notable viewership spikes were observed coinciding with StreamNow promotional campaigns that featured "Meridian" and "Iron Compass" titles. These campaigns included homepage banner placements, push notification campaigns directed to StreamNow subscribers, social media promotions through StreamNow's official channels, and inclusion of Aurelius titles in seasonal and event-driven content curation (e.g., holiday programming blocks, awards season features). The correlation between StreamNow's active promotional efforts and increases in viewership of Aurelius titles further substantiates that StreamNow actively drove audience engagement with the infringing content, rather than merely passively hosting it.

The sustained and platform-promoted nature of the viewership patterns is relevant both to the damages analysis and to the determination that StreamNow cannot credibly claim passive hosting status for purposes of DMCA safe harbor analysis.

VI. REVENUE ATTRIBUTION ANALYSIS

A. Revenue Attribution Methodology

CipherTrace developed a multi-factor revenue attribution model to quantify the economic value that StreamNow derived from the unauthorized exploitation of Aurelius content during the Infringement Period. The model was developed in consultation with Calderwood & Harkness LLP and with reference to preliminary data inputs and methodological guidance from Hargrove Economic Consulting Group, LLC, under the direction of Dr. Elena Vasquez. The Hargrove group is expected to serve as Aurelius's damages expert in connection with anticipated litigation and will provide a separate expert report addressing damages under applicable theories of recovery.

The revenue attribution model attributes StreamNow revenues to Aurelius content across three distinct revenue streams:

(1) Subscription revenue (SVOD): Revenue generated from StreamNow subscriber fees, attributed to Aurelius content based on its proportional viewership share and adjusted for premium-tier weighting factors;

(2) Advertising revenue (AVOD): Revenue generated from advertising impressions served in connection with streams of Aurelius titles on the advertising-supported tier; and

(3) Sublicensing fees from FAST channel operators: Revenue received by StreamNow from third-party FAST channel operators to whom StreamNow sublicensed content bundles containing Aurelius titles.

StreamNow Holdings, Inc. is a privately held corporation, and accordingly, its detailed financial data is not publicly available. For purposes of the revenue attribution analysis, CipherTrace estimated StreamNow's total revenues based on available industry sources and public filings of Pinnacle Ventures Fund III, LP, StreamNow's majority investor. Pinnacle Ventures Fund III, LP holds approximately 62% of StreamNow's fully diluted equity and closed a $145 million Series C investment in StreamNow in June 2022. Based on data derived from these sources, StreamNow's estimated fiscal year 2025 revenue is approximately $312 million. This estimate was used as the basis for revenue calculations, prorated as appropriate over the twenty-two-month Infringement Period.

The detailed methodology, assumptions, data sources, and calculations underlying the revenue attribution model are fully documented in Exhibit E.

B. Subscription Revenue Attribution

StreamNow's estimated twenty-two-month subscription revenue during the Infringement Period is approximately $497.6 million, derived from annualized fiscal year 2025 subscription revenue figures prorated over the twenty-two-month period from April 2024 through January 2026. This figure encompasses subscription fees from all tiers and all geographic territories.

Applying the Aurelius content viewership share of 7.18% to total subscription revenue yields a raw viewership-based attribution of approximately $35.7 million ($497.6 million × 7.18% ≈ $35.7 million). This raw attribution figure represents a starting point for analysis.

CipherTrace's refined revenue attribution model adjusts the raw figure to account for several factors that affect the relationship between viewership share and subscription revenue attribution:

• Premium-Tier Weighting: The model adjusts for the disproportionate concentration of Aurelius titles in premium subscription tiers. While Aurelius content was more heavily promoted within these tiers, the per-title subscription allocation in premium tiers is lower due to the larger overall catalog size at those tiers, requiring a downward adjustment to the raw viewership-based attribution.

• Subscriber Acquisition Value: Conversely, the model adjusts upward to account for the demonstrated subscriber acquisition value of marquee franchise properties, particularly "Meridian" and "Iron Compass." These properties serve as subscription drivers — content that attracts new subscribers and retains existing subscribers — and their value to StreamNow's subscription revenue base exceeds what a simple viewership share calculation would suggest.

• Catalog Depth and Retention Value: The model further accounts for the contribution of the broader Aurelius catalog (beyond the marquee franchises) to subscriber retention, recognizing that the depth and diversity of the Aurelius library provide ongoing value to subscribers who may initially subscribe for marquee titles but remain for the breadth of available content.

After application of these adjustments, the net subscription revenue attributable to Aurelius content is $22,400,000 (twenty-two million four hundred thousand dollars).

C. Advertising Revenue Attribution (AVOD Tier)

All 217 Aurelius titles were available on StreamNow's AVOD tier throughout the Infringement Period, generating advertising impressions each time a viewer streamed an Aurelius title on the advertising-supported tier. The AVOD tier represents a significant and growing revenue stream for StreamNow, as it attracts users who prefer free, ad-supported content access.

CipherTrace analyzed advertising load rates applicable to Aurelius content streams, including pre-roll advertisements (displayed before content playback), mid-roll advertisements (displayed during content playback at designated break points), and display advertisements (overlaid during playback or displayed on content detail pages). Estimated CPM rates were derived from industry benchmarks for premium streaming content in the categories represented by the Aurelius catalog (theatrical films, prestige drama series, and period drama). CipherTrace then applied Aurelius content's proportional share of AVOD viewing hours to StreamNow's estimated AVOD advertising revenue to calculate the advertising revenue attributable to Aurelius content.

The advertising revenue attributable to Aurelius content during the Infringement Period is $9,700,000 (nine million seven hundred thousand dollars).

D. Sublicensing Fee Attribution (FAST Channel Operators)

In addition to distributing Aurelius content directly on its own platform, StreamNow sublicensed content bundles containing Aurelius titles to four third-party FAST channel operators. These sublicensing arrangements generated additional revenue for StreamNow from the exploitation of Aurelius content beyond StreamNow's own platform.

CipherTrace identified the following four sublicensees:

1. Brindoval Channel Networks, Inc. — Dallas, Texas

2. BrightLoop Media, LLC — Miami, Florida

3. Velvet Stream Partners, LP — Toronto, Ontario, Canada

4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia

CipherTrace confirmed the presence of Aurelius titles within the sublicensed content bundles distributed to each of these operators through fingerprinting of the FAST channel content feeds using the CT-AVF Engine. The identification of Aurelius content on each sublicensee's FAST channel is documented in Exhibit F.

Based on estimated sublicensing fee structures (derived from industry benchmarks and available data regarding typical FAST channel content licensing economics) and the proportion of Aurelius content within the sublicensed bundles delivered to each operator, CipherTrace attributes $6,500,000 (six million five hundred thousand dollars) in sublicensing fees received by StreamNow to bundles containing Aurelius titles.

E. Total Revenue Attribution Summary

The following table summarizes the total revenue attributable to Aurelius content across all three revenue streams during the twenty-two-month Infringement Period:

The total estimated revenue attributable to Aurelius content on the StreamNow platform and through StreamNow's sublicensed FAST channel distribution over the twenty-two-month Infringement Period is $38,600,000 (thirty-eight million six hundred thousand dollars). This figure represents the gross revenue derived by StreamNow from its unauthorized exploitation of the Aurelius catalog and will serve as a foundational input for the damages analysis to be conducted by Hargrove Economic Consulting Group, LLC and presented in connection with anticipated litigation.

VII. FAST CHANNEL SUBLICENSEE ANALYSIS

A. Identification of Sublicensees

CipherTrace's forensic analysis extended beyond the StreamNow platform itself to identify and confirm the downstream distribution of Aurelius content through StreamNow's sublicensing relationships with third-party FAST channel operators. FAST channels are free, advertising-supported streaming television channels that distribute linear programming to viewers through connected television devices, mobile applications, and web-based platforms. StreamNow's sublicensing of content bundles to FAST channel operators represents an additional vector of unauthorized distribution of Aurelius content and an additional source of revenue derived from that distribution.

CipherTrace confirmed the presence of Aurelius-owned titles on FAST channels operated by each of the four identified sublicensees through content fingerprinting of their respective channel feeds using the CT-AVF Engine. The results are as follows:

Brindoval Channel Networks, Inc. (Dallas, Texas): CipherTrace identified Aurelius content across two Brindoval-operated FAST channels. Brindoval operates a network of genre-specific FAST channels distributed through major connected television platforms, and Aurelius titles — including titles from the "Thornfield" period drama catalog — were identified on Brindoval's drama and film channels.

BrightLoop Media, LLC (Miami, Florida): CipherTrace identified Aurelius content on one BrightLoop-operated FAST channel. BrightLoop's channel focuses on premium film and series content, and multiple Aurelius feature films were confirmed present in the channel's programming lineup.

Velvet Stream Partners, LP (Toronto, Ontario, Canada): CipherTrace identified Aurelius content on one Velvet Stream-operated FAST channel serving Canadian viewers. The presence of Aurelius content on a Canadian FAST channel extends the geographic scope of the unauthorized distribution into a territory where Aurelius maintains active licensing relationships with authorized Canadian distribution partners.

Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia): CipherTrace identified Aurelius content on one Pacific Lantern-operated FAST channel serving Australian viewers. As with the Canadian distribution, the unauthorized presence of Aurelius content on an Australian FAST channel creates the potential for market interference with Aurelius's authorized distribution arrangements in that territory.

B. Scope of Sublicensed Content

CipherTrace's analysis of the content bundles sublicensed to each of the four FAST channel operators reveals substantial inclusion of Aurelius titles. Each sublicensee received content bundles containing between 40 and 85 Aurelius titles, with significant overlap across the bundles delivered to different operators. In aggregate, the unique Aurelius titles distributed across all four sublicensees totals the full 217 titles in the Aurelius catalog — meaning that every Aurelius title present on the StreamNow platform was also sublicensed to at least one downstream FAST channel operator.

Content was actively streaming on all four sublicensee platforms as of the date of CipherTrace's forensic analysis in late February 2026, confirming that the downstream distribution of Aurelius content through FAST channels remains ongoing.

The identification of Aurelius titles on each sublicensee's FAST channel, including title-by-title fingerprint results, is documented in Exhibit F.

VIII. FINDINGS SUPPORTING ACTIVE CURATION AND DMCA NON-APPLICABILITY

CipherTrace's forensic analysis yields findings that are directly relevant to the legal determination of whether StreamNow may claim safe harbor protection under Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512. A threshold requirement for DMCA safe harbor eligibility is that the service provider function as a passive conduit or host of user-generated or user-uploaded content, without exercising editorial control over the content at issue. CipherTrace's analysis demonstrates that StreamNow does not function as a passive hosting service with respect to the Aurelius content. The specific findings supporting this conclusion include the following:

• StreamNow assigned proprietary internal content identifiers and genre/category classification tags to all 217 Aurelius titles, integrating them into StreamNow's content management system in the same manner as content obtained through authorized licensing arrangements.

• Aurelius titles were placed in curated editorial collections, including "Featured," "Trending," and "Staff Picks" collections, which are prominently displayed on the StreamNow platform and reflect affirmative editorial selection by StreamNow's content programming team.

• StreamNow's recommendation algorithm actively promoted Aurelius titles to users based on their individual viewing histories, preference profiles, and engagement patterns, driving increased viewership and engagement with the infringing content.

• StreamNow exercised control over pricing tier placement of Aurelius titles, determining which titles were available on the SVOD tier (requiring a paid subscription) and which were available on the AVOD tier (free with advertising), and making 183 of 217 titles available on the premium SVOD tier.

• StreamNow determined the geographic availability of Aurelius titles, choosing to make the content available across all 14 of its operating territories without geographic restrictions.

• StreamNow negotiated and executed sublicensing agreements with four third-party FAST channel operators that included Aurelius content within the sublicensed bundles, thereby acting as a commercial distributor of Aurelius content to downstream licensees.

Taken together, these findings establish that StreamNow exercised comprehensive editorial, commercial, and operational control over the Aurelius content — precisely the type of active involvement that distinguishes a content distributor from a passive hosting service. These findings are relevant to the determination that StreamNow does not qualify for DMCA § 512 safe harbor protection and should be held directly liable for copyright infringement arising from its unauthorized reproduction, distribution, public performance, and sublicensing of Aurelius's copyrighted works.

IX. ONGOING NATURE OF INFRINGEMENT

As of CipherTrace's final data collection date of March 1, 2026, all 217 Aurelius-owned audiovisual titles remained available on the StreamNow platform. None of the titles had been removed, restricted, or made unavailable in any territory. Similarly, Aurelius content remained actively streaming on the four FAST channel sublicensee platforms operated by Brindoval Channel Networks, BrightLoop Media, Velvet Stream Partners, and Pacific Lantern Digital.

New viewership data obtained during the final days of the data collection period indicates that the infringement is ongoing beyond the January 31, 2026 measurement cutoff used for the revenue attribution analysis. Streams of Aurelius content continued during February 2026 at rates consistent with the sustained viewing patterns observed throughout the Infringement Period, and additional revenue continued to accrue to StreamNow and its sublicensees.

CipherTrace is prepared to update its forensic analysis to capture continued infringement through the date of any injunctive relief, takedown, or other cessation of infringing activity. This capability will be important in connection with any motion for a temporary restraining order or preliminary injunction, as well as for calculating ongoing damages through the date of resolution.

X. KEY EXHIBITS AND SUPPORTING MATERIALS

A. List of Exhibits Prepared by CipherTrace

CipherTrace has prepared the following exhibits in connection with its forensic analysis, each of which is available for review by the engagement team and for inclusion in the pre-suit demand and anticipated litigation filings:

Exhibit A: Complete list of all 217 Aurelius-owned audiovisual titles confirmed present on the StreamNow platform, with individual fingerprint match confidence scores, content ingestion dates, and tier availability designations (SVOD, AVOD, or both) for each title. The exhibit is organized by content category (feature films; television series with individual episode listings) and includes title, year of release, running time, and Aurelius copyright registration numbers where available.

Exhibit B: Content ingestion timeline chart illustrating the batch upload dates for the Aurelius content catalog, including the initial batch ingestion (approximately March 28 – April 5, 2024, covering 197 titles) and the secondary batch ingestion (approximately May 15 – June 30, 2024, covering 20 titles). The chart provides a visual representation of the relationship between the ingestion timeline and the date of the purported Content Distribution Agreement between MDD and StreamNow.

Exhibit C: Geographic distribution map showing the availability of Aurelius titles across StreamNow's fourteen operating territories. The map identifies each territory and confirms that no geographic restrictions were applied to the Aurelius content.

Exhibit D: Viewership data tables presenting monthly stream counts, unique viewer counts, and aggregate viewing hours for Aurelius titles for each month of the Infringement Period (April 2024 through January 2026). The tables include breakdowns by platform tier (SVOD and AVOD) and by territory where data is available.

Exhibit E: Revenue attribution model documentation, including the detailed methodology, underlying assumptions, data sources, and step-by-step calculations for the subscription revenue attribution ($22.4 million), advertising revenue attribution ($9.7 million), and sublicensing fee attribution ($6.5 million). The exhibit includes sensitivity analyses illustrating the impact of alternative assumptions on the revenue attribution figures.

Exhibit F: FAST channel sublicensee content identification results, presenting fingerprint matching results for each of the four sublicensees (Brindoval Channel Networks, BrightLoop Media, Velvet Stream Partners, and Pacific Lantern Digital), with complete title lists identifying the Aurelius titles confirmed present on each sublicensee's FAST channel or channels.

Exhibit G: Screenshots and platform metadata captures documenting StreamNow's editorial curation of Aurelius titles, including evidence of placement in "Featured," "Trending," and "Staff Picks" editorial collections, recommendation algorithm data showing active promotion of Aurelius titles to StreamNow users, and display of Aurelius branding and production credits on the StreamNow platform.

Exhibit H: Chain-of-custody documentation for all reference materials received from Aurelius Media Americas, Inc. and for all data sets extracted during the forensic analysis, including timestamps, hash values, and custodian records.

B. Expert Report Availability

Dr. Nathan Frey is prepared to issue a formal expert report suitable for filing in the United States District Court for the Central District of California, in compliance with Federal Rule of Civil Procedure 26(a)(2)(B). Dr. Frey is further prepared to provide testimony in support of a motion for a temporary restraining order and/or preliminary injunction and to testify at trial, if required.

The estimated completion date for the formal expert report is April 2026, subject to adjustments based on the litigation timeline and any additional data collection or analysis requested by the engagement team or required by developments in the case.

XI. CONCLUSIONS

Based on the forensic analysis conducted by CipherTrace Analytics, LLC, the following principal conclusions are supported:

1. CipherTrace's content fingerprinting analysis confirms that all 217 Aurelius-owned audiovisual works — comprising 142 feature films and 75 television series encompassing 1,038 individual episodes — are present on the StreamNow platform and have been available for streaming since approximately April 1, 2024, a period of at least twenty-two months.

2. The content was ingested into the StreamNow platform shortly after the March 15, 2024 date of the purported Content Distribution Agreement between Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager; California Secretary of State File No. 202115729430; business address: 8912 Burton Way, Suite 200, Beverly Hills, California 90211) and StreamNow Holdings, Inc. (Delaware File No. 7291843; headquarters: 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010).

3. StreamNow actively curated, editorially promoted, and commercially monetized the Aurelius content across its subscription (SVOD), advertising-supported (AVOD), and sublicensing revenue channels, generating an estimated total of $38.6 million in attributable revenue during the Infringement Period.

4. The Aurelius content was distributed to viewers in all fourteen countries in which StreamNow operates and was sublicensed to four downstream FAST channel operators — Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd — without authorization from Aurelius.

5. StreamNow's active curation, editorial promotion, tier placement, geographic distribution, and downstream sublicensing of the Aurelius content demonstrates that StreamNow functioned as a commercial content distributor, not a passive hosting service, and accordingly does not qualify for DMCA § 512 safe harbor protection.

6. The infringement is ongoing as of March 1, 2026, with all 217 titles remaining available on the StreamNow platform and on the four FAST channel sublicensee platforms.

7. These findings provide a strong technical and evidentiary foundation for the pre-suit demand and anticipated litigation against StreamNow Holdings, Inc. and potentially against MDD, Franklin Ogilvie, and the FAST channel sublicensees, as may be determined by the engagement team in consultation with the client.

XII. PREPARATION AND DISTRIBUTION

Prepared by:

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

Email: osiddiqui@calderwoodharkness.com

Reviewed by:

Wendy Schultz, Senior Associate Calderwood & Harkness LLP

Based on:

CipherTrace Analytics, LLC preliminary findings report delivered to Calderwood & Harkness LLP on March 3, 2026; supporting data sets and exhibits provided by CipherTrace under the terms of the expert retention letter dated February 18, 2026.

Matter No.: 1017-00003

Distribution:

Engagement Team:

• Marcus Delgado, Partner, Calderwood & Harkness LLP

• Catherine Bloom, Partner, Calderwood & Harkness LLP

• Wendy Schultz, Senior Associate, Calderwood & Harkness LLP

• Omar Siddiqui, Associate, Calderwood & Harkness LLP

Client Representatives:

• Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC

• Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Media Americas, Inc.

ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL This memorandum constitutes attorney work product prepared in anticipation of litigation and is protected by the attorney-client privilege and work product doctrine. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this document in error, please notify the sender immediately and destroy all copies.

Revenue Stream	Attributed Amount
Subscription revenue (SVOD)	$22,400,000
Advertising revenue (AVOD)	$9,700,000
Sublicensing fees (FAST channels)	$6,500,000
Total Attributable Revenue	$38,600,000

CALDERWOOD & HARKNESS LLP
Intellectual Property Group
1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200 | Facsimile: (310) 555-7201
ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL This memorandum constitutes attorney work product prepared in anticipation of litigation and is protected by the attorney-client privilege and work product doctrine. Distribution is restricted to the engagement team and client representatives authorized to receive privileged communications. Any unauthorized review, use, disclosure, or distribution is strictly prohibited.
MEMORANDUM
TO: Wendy Schultz, Senior Associate; Marcus Delgado, Partner
FROM: Omar Siddiqui, Associate
DATE: March 5, 2026
RE: Summary of CipherTrace Analytics, LLC Forensic Analysis — StreamNow Holdings, Inc. Platform
CLIENT: Aurelius Global Media Group PLC
MATTER NO.: 1017-00003
I. PURPOSE AND SCOPE OF THIS SUMMARY
This memorandum summarizes the technical and forensic findings of CipherTrace Analytics, LLC ("CipherTrace"), retained by Calderwood & Harkness LLP on behalf of Aurelius Global Media Group PLC ("Aurelius" or "AGMG") pursuant to the expert retention letter dated February 18, 2026. CipherTrace was engaged to perform a comprehensive digital forensic analysis of the StreamNow Holdings, Inc. ("StreamNow") streaming platform to evaluate and document the unauthorized presence, distribution, and monetization of Aurelius-owned audiovisual works on that platform.
Specifically, CipherTrace was engaged to accomplish four primary objectives:
(a) confirm the presence of Aurelius-owned audiovisual works on the StreamNow platform through proprietary audio-visual content fingerprinting technology;
(b) extract and analyze platform metadata regarding dates of content ingestion, content classification, tier assignment, and geographic availability of Aurelius titles within the StreamNow ecosystem;
(c) analyze viewership and traffic data attributable to Aurelius titles, including total stream counts, unique viewer counts, and aggregate viewing hours over the relevant period; and
(d) model revenue attribution across StreamNow's subscription (SVOD), advertising-supported (AVOD), and sublicensing revenue streams, quantifying the economic value StreamNow derived from the unauthorized exploitation of Aurelius's content catalog.
The analysis was conducted under the supervision and direction of Dr. Nathan Frey, Director of Digital Media Forensics at CipherTrace Analytics, LLC, located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. Dr. Frey served as the engagement lead and is prepared to serve as the firm's testifying expert in connection with this matter.
The forensic analysis covers the twenty-two-month infringement period from approximately April 1, 2024 through January 31, 2026 (the "Infringement Period"), during which time all 217 Aurelius-owned audiovisual titles were present and available for streaming on the StreamNow platform without authorization from Aurelius or any entity lawfully empowered to grant such rights.
This summary has been prepared for use by the engagement team in connection with pre-suit demand proceedings directed to StreamNow Holdings, Inc. and its principals, and to support anticipated litigation in the United States District Court for the Central District of California. The findings documented herein are based on CipherTrace's preliminary findings report, which was delivered to Calderwood & Harkness on March 3, 2026, together with supporting data sets and exhibits furnished under the terms of the expert retention letter.
II. CIPHERTRACE ANALYTICS — QUALIFICATIONS AND METHODOLOGY OVERVIEW
A. Firm Background and Expert Qualifications
CipherTrace Analytics, LLC is a Delaware limited liability company headquartered at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. The firm specializes in digital media forensics, content identification and verification, and revenue attribution analysis for entertainment and technology-related litigation. CipherTrace has been retained as a forensic expert in matters involving major motion picture studios, television production companies, music publishers, and digital platform operators across a range of intellectual property disputes. The firm maintains state-of-the-art forensic laboratories and computing infrastructure designed to handle large-scale content fingerprinting and metadata analysis.
The CipherTrace engagement team for this matter was led by Dr. Nathan Frey, Director of Digital Media Forensics. Dr. Frey holds a Ph.D. in Computer Science from Stanford University, with a specialization in audio-visual fingerprinting and digital watermarking technologies. He has over fifteen years of professional experience in content protection forensics, and has served as a testifying expert in more than thirty federal copyright infringement cases in U.S. District Courts across multiple circuits. His expert testimony has been admitted without challenge under the Daubert standard, and his published research on audio-visual fingerprinting methodologies has been cited by peer-reviewed journals and federal courts alike. Dr. Frey's curriculum vitae is maintained on file and will be included as an appendix to his formal expert report.
The engagement was further supported by a team of six senior analysts with specialized expertise in metadata extraction from digital streaming platforms, streaming platform architecture and content delivery network analysis, and econometric modeling of digital media revenues. The combined expertise of the CipherTrace engagement team ensures that the findings presented herein reflect the application of best-in-class forensic techniques and industry-standard analytical methods.
B. Methodology Summary
CipherTrace employed a multi-phase forensic methodology encompassing content fingerprinting, metadata extraction, viewership analysis, and revenue attribution modeling. Each phase is summarized below.
Content Fingerprinting. CipherTrace deployed its proprietary audio-visual fingerprinting technology, designated as the CT-AVF Engine v.4.2, to compare reference copies of the 217 Aurelius-owned audiovisual titles against content available on the StreamNow platform. The 217 titles comprise 142 feature films and 75 television series, the latter encompassing a total of 1,038 individual episodes. Reference materials — consisting of digital masters and authorized distribution copies — were provided by Aurelius Media Americas, Inc., located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067, through its Head of Digital Rights Enforcement, Lena Kowalski. The CT-AVF Engine employs a dual-modality matching approach that analyzes both audio waveform signatures and visual frame composition to generate a composite confidence score for each content match. This dual-modality approach significantly reduces the risk of false positives and ensures that matches are accurate and defensible.
Metadata Extraction. CipherTrace extracted platform metadata from the StreamNow platform, including content identifiers (both internal and external-facing), ingestion timestamps, content classification tags (genre, rating, language), geographic distribution flags, and tier availability indicators (subscription tier versus advertising-supported tier). Metadata was obtained through analysis of publicly accessible StreamNow platform interfaces, publicly available application programming interface ("API") endpoints, and structured data embedded in the platform's content delivery architecture. All extracted metadata was preserved in forensically sound format with appropriate chain-of-custody documentation.
Viewership and Traffic Analysis. CipherTrace analyzed publicly available viewership metrics published by StreamNow, third-party audience measurement data from recognized industry measurement services, and platform engagement indicators (including trending lists, editorial features, and recommendation algorithm outputs) to estimate total streams, unique viewer counts, and aggregate viewing hours attributable to Aurelius titles during the Infringement Period. Where StreamNow's proprietary viewership data was not publicly available, CipherTrace employed validated estimation methodologies consistent with accepted industry practices for digital streaming audience measurement.
Revenue Attribution Modeling. CipherTrace developed a multi-factor econometric model to attribute StreamNow's revenues to the Aurelius content catalog across three distinct revenue streams: subscription revenue (SVOD), advertising revenue (AVOD), and sublicensing fees received from third-party FAST (Free Ad-Supported Streaming Television) channel operators. The revenue attribution model incorporates viewership share analysis, premium-tier weighting adjustments to account for the disproportionate presence of Aurelius titles in higher-value subscription tiers, advertising CPM (cost per thousand impressions) data derived from industry benchmarks, and sublicensing fee allocation based on the proportional representation of Aurelius content within sublicensed content bundles. The model was developed in consultation with Calderwood & Harkness and with reference to preliminary data inputs from Hargrove Economic Consulting Group, LLC, under the direction of Dr. Elena Vasquez.
Data Collection Period. Forensic data collection was conducted between February 18, 2026 and March 1, 2026. The analysis encompasses historical data spanning the full Infringement Period from April 1, 2024 through January 31, 2026.
Quality Controls. All findings presented in this summary and in CipherTrace's preliminary findings report have been subjected to internal peer review within CipherTrace Analytics. Chain-of-custody documentation has been maintained for all reference materials received from Aurelius Media Americas, Inc. and for all data sets extracted during the forensic analysis. The integrity of the forensic process is documented in Exhibit H and will be fully described in Dr. Frey's formal expert report.
III. CONTENT FINGERPRINTING RESULTS — CONFIRMATION OF INFRINGING TITLES
A. Overview of Findings
CipherTrace's CT-AVF Engine v.4.2 confirmed the presence of all 217 Aurelius-owned audiovisual titles on the StreamNow platform during the Infringement Period. The confirmed titles consist of 142 feature films and 75 television series, with the television series comprising a total of 1,038 individual episodes. The fingerprinting analysis was performed against reference copies of each title provided by Aurelius Media Americas, Inc. and yielded a match confidence level of 99.7% or higher for every one of the 217 titles, based on the CT-AVF Engine's combined audio waveform and visual frame matching methodology. No Aurelius title returned a match confidence score below 99.7%, and the vast majority of titles matched at 99.9% confidence or above. These confidence levels are well within the threshold for forensic certainty as recognized in peer-reviewed literature on audio-visual content identification.
The complete list of all 217 confirmed titles, together with their individual fingerprint match confidence scores, ingestion dates, and tier availability designations, is set forth in Exhibit A to this memorandum.
B. Key Franchise Identification
Among the 217 confirmed titles, several high-profile Aurelius franchise properties warrant particular attention due to their commercial significance, brand value, and outsized contribution to StreamNow's viewership and revenue metrics.
"Meridian" Franchise. All six films in the "Meridian" franchise were confirmed present on the StreamNow platform. The "Meridian" franchise is Aurelius's flagship theatrical film property, with combined global box office receipts of approximately $1.43 billion across six installments. Each of the six films returned a fingerprint match confidence score of 99.9%. The franchise is among the most commercially valuable and widely recognized film properties in Aurelius's catalog, and its unauthorized presence on StreamNow represents a significant portion of the damages at issue.
"Iron Compass" Series. All four seasons of the "Iron Compass" television series, comprising a total of 48 episodes, were confirmed present on the StreamNow platform. "Iron Compass" is Aurelius's highest-rated original television series, averaging approximately 9.2 million UK viewers per episode during its initial broadcast run. The series has won numerous industry awards and maintains a substantial and loyal global audience, making it a highly attractive content asset for any streaming platform.
"Thornfield" Period Drama Catalog. All 12 titles in the "Thornfield" period drama catalog were confirmed present on the StreamNow platform. The "Thornfield" catalog has been recognized with seven British Academy of Film and Television Arts ("BAFTA") awards, establishing it as one of the most critically acclaimed collections of period drama programming in the world.
The remaining confirmed titles consist of 124 additional feature films and 63 additional television series, all of which were confirmed present on the StreamNow platform via fingerprint matching at confidence levels of 99.7% or above. The full details of each title, including individual confidence scores, are presented in Exhibit A.
C. Content Integrity Analysis
CipherTrace's forensic analysis further establishes that the Aurelius titles available on the StreamNow platform were streamed in substantially identical form to the original masters provided by Aurelius Media Americas, Inc. as reference copies. CipherTrace found no evidence of re-encoding, alteration, editing, or transformation that would materially distinguish the copies hosted on StreamNow's platform from Aurelius's authorized versions of the same works. The audio and visual content of the StreamNow copies is, for all forensic purposes, identical to the Aurelius originals.
Additionally, CipherTrace observed that the StreamNow platform displayed Aurelius branding, production credits, and copyright notices on certain titles, further confirming the provenance of the content and establishing that StreamNow was aware — or should have been aware — that the titles originated from Aurelius's catalog. The display of Aurelius branding on the StreamNow platform is documented in screenshots and metadata captures preserved in Exhibit G.
IV. METADATA EXTRACTION — INGESTION DATES AND PLATFORM INTEGRATION
A. Content Ingestion Timeline
CipherTrace's extraction and analysis of StreamNow platform metadata reveals that the 217 Aurelius-owned audiovisual titles were ingested into the StreamNow platform content library beginning on or about April 1, 2024. The ingestion occurred in two distinct phases.
The initial batch ingestion took place over approximately nine days, from approximately March 28, 2024 through April 5, 2024. This initial batch comprised 197 of the 217 Aurelius titles. The timing of this initial batch ingestion corresponds closely to the date of the purported Content Distribution Agreement between Meridian Digital Distributors, LLC ("MDD") and StreamNow Holdings, Inc., which was allegedly executed on March 15, 2024. The proximity between the date of the purported agreement and the commencement of content ingestion suggests that StreamNow began uploading Aurelius titles to its platform promptly upon execution of the agreement with MDD — an entity whose authority to distribute Aurelius content is directly at issue in this matter.
A secondary batch ingestion took place between approximately May 15, 2024 and June 30, 2024, during which the remaining 20 Aurelius titles were added to the StreamNow platform library. These 20 titles appear to have been titles that were either not included in the initial content delivery from MDD or that required additional processing before ingestion.
Critically, all 217 Aurelius titles remained continuously available on the StreamNow platform through at least January 31, 2026, which marks the end of the measured Infringement Period. This constitutes a period of approximately twenty-two months of uninterrupted availability. No titles were removed, taken down, or made unavailable at any point during this period. The content ingestion timeline is illustrated graphically in Exhibit B.
B. Content Classification and Tier Assignment
CipherTrace's metadata extraction further reveals that Aurelius titles were classified within StreamNow's platform architecture under premium content tiers, reflecting StreamNow's recognition of the high commercial value of the Aurelius catalog. Specifically, 183 of the 217 Aurelius titles were made available on the subscription (SVOD) tier, which requires users to maintain a paid subscription to access content. All 217 Aurelius titles were additionally made available on the advertising-supported (AVOD) tier, which permits free access to content with advertising interruptions.
The placement of the majority of Aurelius titles in the SVOD tier is particularly significant because it indicates that StreamNow used Aurelius content as part of its paid subscription value proposition — a function that directly drives subscriber acquisition and retention and generates premium subscription revenues.
Moreover, CipherTrace's analysis of StreamNow's editorial curation metadata confirms that the "Meridian" franchise films and the "Iron Compass" series were featured in StreamNow's curated "Featured" and "Trending" editorial collections. These curated collections are prominently displayed on StreamNow's homepage and within the platform's browsing interface, and are the primary mechanism through which StreamNow drives user attention and engagement toward specific content. The placement of Aurelius titles in these curated collections constitutes active editorial curation by StreamNow — not passive hosting — and demonstrates that StreamNow exercised editorial judgment and control over the presentation and promotion of Aurelius content to its subscribers and viewers.
All Aurelius content was further tagged with StreamNow-generated internal content identifiers, genre classifications, content ratings, and recommendation algorithm metadata. This metadata integration demonstrates that the Aurelius titles were fully incorporated into StreamNow's content management and distribution infrastructure, including its automated recommendation engine, which actively promotes content to users based on viewing history, preferences, and engagement patterns.
C. Geographic Distribution
CipherTrace's metadata analysis confirms that Aurelius titles were made available for streaming across all fourteen countries in which StreamNow operates its platform. These territories include the United States, Canada, Australia, and eleven additional international territories spanning Europe, Latin America, and the Asia-Pacific region. No geographic restrictions or geo-blocking measures were applied specifically to Aurelius content. The titles were distributed globally across StreamNow's entire geographic footprint, maximizing the exposure and reach of the infringing content and amplifying the scope of Aurelius's resulting damages.
The geographic distribution of Aurelius titles across StreamNow's operating territories is illustrated in the geographic distribution map attached as Exhibit C.
V. VIEWERSHIP AND TRAFFIC DATA ANALYSIS
A. Aggregate Viewership Metrics
CipherTrace's analysis of viewership and traffic data attributable to Aurelius titles on the StreamNow platform during the twenty-two-month Infringement Period reveals substantial and sustained audience engagement with the infringing content.
Over the Infringement Period, Aurelius titles generated an estimated total of approximately 84.3 million streams across all territories and platform tiers (SVOD and AVOD combined). This figure encompasses streams of individual feature films and individual television series episodes, counted each time a viewer initiated playback of an Aurelius title.
The estimated number of unique viewer accounts that accessed Aurelius content during the Infringement Period is approximately 12.6 million unique accounts. This figure reflects distinct StreamNow user accounts that streamed at least one Aurelius title during the relevant period and provides an indication of the breadth of the audience that was exposed to Aurelius's content through StreamNow's unauthorized distribution.
Total viewing hours attributable to Aurelius titles during the Infringement Period are estimated at approximately 147 million hours. This aggregate viewing time metric is a key input into the revenue attribution model, particularly for advertising revenue attribution, where viewing duration directly correlates with advertising impression volume and advertising revenue generation.
Detailed monthly viewership data — including stream counts, unique viewer figures, and viewing hours — for each month of the Infringement Period is set forth in Exhibit D.
B. Viewership Share Analysis
To contextualize the viewership data and to support the revenue attribution model, CipherTrace calculated the viewership share of Aurelius titles as a proportion of total StreamNow platform streams during the Infringement Period.
Aurelius titles accounted for approximately 7.18% of total StreamNow streams during the Infringement Period. This viewership share was calculated based on total platform stream counts derived from third-party audience measurement data published by recognized industry measurement services and from StreamNow's own publicly reported engagement metrics, including quarterly and annual disclosures made in connection with investor communications and press releases.
A viewership share of 7.18% is significant for a single content licensor's catalog on a diversified streaming platform, particularly given that StreamNow's platform hosts content from hundreds of content providers. This disproportionate viewership share reflects the premium quality and broad audience appeal of the Aurelius catalog, especially its marquee franchise properties.
Among individual franchise properties, the "Meridian" franchise alone accounted for approximately 1.9% of total platform streams during the Infringement Period, making it one of the single highest-performing content sets on the StreamNow platform. The six "Meridian" films consistently ranked among StreamNow's most-streamed titles in monthly and quarterly performance metrics.
The "Iron Compass" television series contributed approximately 1.4% of total platform streams during the Infringement Period, reflecting the series' strong and loyal audience base and its appeal to the streaming platform's demographic profile.
The remaining Aurelius titles collectively accounted for approximately 3.88% of total platform streams, demonstrating that the value of the Aurelius catalog extends well beyond its marquee franchises and encompasses a deep library of commercially valuable content.
C. Viewership Trends
CipherTrace's temporal analysis of viewership patterns reveals that viewership of Aurelius content remained consistently high throughout the twenty-two-month Infringement Period. There was no significant decline in viewership over time, indicating sustained audience demand for Aurelius titles and ongoing platform-driven promotion of the content.
Notable viewership spikes were observed coinciding with StreamNow promotional campaigns that featured "Meridian" and "Iron Compass" titles. These campaigns included homepage banner placements, push notification campaigns directed to StreamNow subscribers, social media promotions through StreamNow's official channels, and inclusion of Aurelius titles in seasonal and event-driven content curation (e.g., holiday programming blocks, awards season features). The correlation between StreamNow's active promotional efforts and increases in viewership of Aurelius titles further substantiates that StreamNow actively drove audience engagement with the infringing content, rather than merely passively hosting it.
The sustained and platform-promoted nature of the viewership patterns is relevant both to the damages analysis and to the determination that StreamNow cannot credibly claim passive hosting status for purposes of DMCA safe harbor analysis.
VI. REVENUE ATTRIBUTION ANALYSIS
A. Revenue Attribution Methodology
CipherTrace developed a multi-factor revenue attribution model to quantify the economic value that StreamNow derived from the unauthorized exploitation of Aurelius content during the Infringement Period. The model was developed in consultation with Calderwood & Harkness LLP and with reference to preliminary data inputs and methodological guidance from Hargrove Economic Consulting Group, LLC, under the direction of Dr. Elena Vasquez. The Hargrove group is expected to serve as Aurelius's damages expert in connection with anticipated litigation and will provide a separate expert report addressing damages under applicable theories of recovery.
The revenue attribution model attributes StreamNow revenues to Aurelius content across three distinct revenue streams:
(1) Subscription revenue (SVOD): Revenue generated from StreamNow subscriber fees, attributed to Aurelius content based on its proportional viewership share and adjusted for premium-tier weighting factors;
(2) Advertising revenue (AVOD): Revenue generated from advertising impressions served in connection with streams of Aurelius titles on the advertising-supported tier; and
(3) Sublicensing fees from FAST channel operators: Revenue received by StreamNow from third-party FAST channel operators to whom StreamNow sublicensed content bundles containing Aurelius titles.
StreamNow Holdings, Inc. is a privately held corporation, and accordingly, its detailed financial data is not publicly available. For purposes of the revenue attribution analysis, CipherTrace estimated StreamNow's total revenues based on available industry sources and public filings of Pinnacle Ventures Fund III, LP, StreamNow's majority investor. Pinnacle Ventures Fund III, LP holds approximately 62% of StreamNow's fully diluted equity and closed a $145 million Series C investment in StreamNow in June 2022. Based on data derived from these sources, StreamNow's estimated fiscal year 2025 revenue is approximately $312 million. This estimate was used as the basis for revenue calculations, prorated as appropriate over the twenty-two-month Infringement Period.
The detailed methodology, assumptions, data sources, and calculations underlying the revenue attribution model are fully documented in Exhibit E.
B. Subscription Revenue Attribution
StreamNow's estimated twenty-two-month subscription revenue during the Infringement Period is approximately $497.6 million, derived from annualized fiscal year 2025 subscription revenue figures prorated over the twenty-two-month period from April 2024 through January 2026. This figure encompasses subscription fees from all tiers and all geographic territories.
Applying the Aurelius content viewership share of 7.18% to total subscription revenue yields a raw viewership-based attribution of approximately $35.7 million ($497.6 million × 7.18% ≈ $35.7 million). This raw attribution figure represents a starting point for analysis.
CipherTrace's refined revenue attribution model adjusts the raw figure to account for several factors that affect the relationship between viewership share and subscription revenue attribution:
• Premium-Tier Weighting: The model adjusts for the disproportionate concentration of Aurelius titles in premium subscription tiers. While Aurelius content was more heavily promoted within these tiers, the per-title subscription allocation in premium tiers is lower due to the larger overall catalog size at those tiers, requiring a downward adjustment to the raw viewership-based attribution.
• Subscriber Acquisition Value: Conversely, the model adjusts upward to account for the demonstrated subscriber acquisition value of marquee franchise properties, particularly "Meridian" and "Iron Compass." These properties serve as subscription drivers — content that attracts new subscribers and retains existing subscribers — and their value to StreamNow's subscription revenue base exceeds what a simple viewership share calculation would suggest.
• Catalog Depth and Retention Value: The model further accounts for the contribution of the broader Aurelius catalog (beyond the marquee franchises) to subscriber retention, recognizing that the depth and diversity of the Aurelius library provide ongoing value to subscribers who may initially subscribe for marquee titles but remain for the breadth of available content.
After application of these adjustments, the net subscription revenue attributable to Aurelius content is $22,400,000 (twenty-two million four hundred thousand dollars).
C. Advertising Revenue Attribution (AVOD Tier)
All 217 Aurelius titles were available on StreamNow's AVOD tier throughout the Infringement Period, generating advertising impressions each time a viewer streamed an Aurelius title on the advertising-supported tier. The AVOD tier represents a significant and growing revenue stream for StreamNow, as it attracts users who prefer free, ad-supported content access.
CipherTrace analyzed advertising load rates applicable to Aurelius content streams, including pre-roll advertisements (displayed before content playback), mid-roll advertisements (displayed during content playback at designated break points), and display advertisements (overlaid during playback or displayed on content detail pages). Estimated CPM rates were derived from industry benchmarks for premium streaming content in the categories represented by the Aurelius catalog (theatrical films, prestige drama series, and period drama). CipherTrace then applied Aurelius content's proportional share of AVOD viewing hours to StreamNow's estimated AVOD advertising revenue to calculate the advertising revenue attributable to Aurelius content.
The advertising revenue attributable to Aurelius content during the Infringement Period is $9,700,000 (nine million seven hundred thousand dollars).
D. Sublicensing Fee Attribution (FAST Channel Operators)
In addition to distributing Aurelius content directly on its own platform, StreamNow sublicensed content bundles containing Aurelius titles to four third-party FAST channel operators. These sublicensing arrangements generated additional revenue for StreamNow from the exploitation of Aurelius content beyond StreamNow's own platform.
CipherTrace identified the following four sublicensees:
1. Brindoval Channel Networks, Inc. — Dallas, Texas
2. BrightLoop Media, LLC — Miami, Florida
3. Velvet Stream Partners, LP — Toronto, Ontario, Canada
4. Pacific Lantern Digital Pty Ltd — Sydney, New South Wales, Australia
CipherTrace confirmed the presence of Aurelius titles within the sublicensed content bundles distributed to each of these operators through fingerprinting of the FAST channel content feeds using the CT-AVF Engine. The identification of Aurelius content on each sublicensee's FAST channel is documented in Exhibit F.
Based on estimated sublicensing fee structures (derived from industry benchmarks and available data regarding typical FAST channel content licensing economics) and the proportion of Aurelius content within the sublicensed bundles delivered to each operator, CipherTrace attributes $6,500,000 (six million five hundred thousand dollars) in sublicensing fees received by StreamNow to bundles containing Aurelius titles.
E. Total Revenue Attribution Summary
The following table summarizes the total revenue attributable to Aurelius content across all three revenue streams during the twenty-two-month Infringement Period:
The total estimated revenue attributable to Aurelius content on the StreamNow platform and through StreamNow's sublicensed FAST channel distribution over the twenty-two-month Infringement Period is $38,600,000 (thirty-eight million six hundred thousand dollars). This figure represents the gross revenue derived by StreamNow from its unauthorized exploitation of the Aurelius catalog and will serve as a foundational input for the damages analysis to be conducted by Hargrove Economic Consulting Group, LLC and presented in connection with anticipated litigation.
VII. FAST CHANNEL SUBLICENSEE ANALYSIS
A. Identification of Sublicensees
CipherTrace's forensic analysis extended beyond the StreamNow platform itself to identify and confirm the downstream distribution of Aurelius content through StreamNow's sublicensing relationships with third-party FAST channel operators. FAST channels are free, advertising-supported streaming television channels that distribute linear programming to viewers through connected television devices, mobile applications, and web-based platforms. StreamNow's sublicensing of content bundles to FAST channel operators represents an additional vector of unauthorized distribution of Aurelius content and an additional source of revenue derived from that distribution.
CipherTrace confirmed the presence of Aurelius-owned titles on FAST channels operated by each of the four identified sublicensees through content fingerprinting of their respective channel feeds using the CT-AVF Engine. The results are as follows:
Brindoval Channel Networks, Inc. (Dallas, Texas): CipherTrace identified Aurelius content across two Brindoval-operated FAST channels. Brindoval operates a network of genre-specific FAST channels distributed through major connected television platforms, and Aurelius titles — including titles from the "Thornfield" period drama catalog — were identified on Brindoval's drama and film channels.
BrightLoop Media, LLC (Miami, Florida): CipherTrace identified Aurelius content on one BrightLoop-operated FAST channel. BrightLoop's channel focuses on premium film and series content, and multiple Aurelius feature films were confirmed present in the channel's programming lineup.
Velvet Stream Partners, LP (Toronto, Ontario, Canada): CipherTrace identified Aurelius content on one Velvet Stream-operated FAST channel serving Canadian viewers. The presence of Aurelius content on a Canadian FAST channel extends the geographic scope of the unauthorized distribution into a territory where Aurelius maintains active licensing relationships with authorized Canadian distribution partners.
Pacific Lantern Digital Pty Ltd (Sydney, New South Wales, Australia): CipherTrace identified Aurelius content on one Pacific Lantern-operated FAST channel serving Australian viewers. As with the Canadian distribution, the unauthorized presence of Aurelius content on an Australian FAST channel creates the potential for market interference with Aurelius's authorized distribution arrangements in that territory.
B. Scope of Sublicensed Content
CipherTrace's analysis of the content bundles sublicensed to each of the four FAST channel operators reveals substantial inclusion of Aurelius titles. Each sublicensee received content bundles containing between 40 and 85 Aurelius titles, with significant overlap across the bundles delivered to different operators. In aggregate, the unique Aurelius titles distributed across all four sublicensees totals the full 217 titles in the Aurelius catalog — meaning that every Aurelius title present on the StreamNow platform was also sublicensed to at least one downstream FAST channel operator.
Content was actively streaming on all four sublicensee platforms as of the date of CipherTrace's forensic analysis in late February 2026, confirming that the downstream distribution of Aurelius content through FAST channels remains ongoing.
The identification of Aurelius titles on each sublicensee's FAST channel, including title-by-title fingerprint results, is documented in Exhibit F.
VIII. FINDINGS SUPPORTING ACTIVE CURATION AND DMCA NON-APPLICABILITY
CipherTrace's forensic analysis yields findings that are directly relevant to the legal determination of whether StreamNow may claim safe harbor protection under Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512. A threshold requirement for DMCA safe harbor eligibility is that the service provider function as a passive conduit or host of user-generated or user-uploaded content, without exercising editorial control over the content at issue. CipherTrace's analysis demonstrates that StreamNow does not function as a passive hosting service with respect to the Aurelius content. The specific findings supporting this conclusion include the following:
• StreamNow assigned proprietary internal content identifiers and genre/category classification tags to all 217 Aurelius titles, integrating them into StreamNow's content management system in the same manner as content obtained through authorized licensing arrangements.
• Aurelius titles were placed in curated editorial collections, including "Featured," "Trending," and "Staff Picks" collections, which are prominently displayed on the StreamNow platform and reflect affirmative editorial selection by StreamNow's content programming team.
• StreamNow's recommendation algorithm actively promoted Aurelius titles to users based on their individual viewing histories, preference profiles, and engagement patterns, driving increased viewership and engagement with the infringing content.
• StreamNow exercised control over pricing tier placement of Aurelius titles, determining which titles were available on the SVOD tier (requiring a paid subscription) and which were available on the AVOD tier (free with advertising), and making 183 of 217 titles available on the premium SVOD tier.
• StreamNow determined the geographic availability of Aurelius titles, choosing to make the content available across all 14 of its operating territories without geographic restrictions.
• StreamNow negotiated and executed sublicensing agreements with four third-party FAST channel operators that included Aurelius content within the sublicensed bundles, thereby acting as a commercial distributor of Aurelius content to downstream licensees.
Taken together, these findings establish that StreamNow exercised comprehensive editorial, commercial, and operational control over the Aurelius content — precisely the type of active involvement that distinguishes a content distributor from a passive hosting service. These findings are relevant to the determination that StreamNow does not qualify for DMCA § 512 safe harbor protection and should be held directly liable for copyright infringement arising from its unauthorized reproduction, distribution, public performance, and sublicensing of Aurelius's copyrighted works.
IX. ONGOING NATURE OF INFRINGEMENT
As of CipherTrace's final data collection date of March 1, 2026, all 217 Aurelius-owned audiovisual titles remained available on the StreamNow platform. None of the titles had been removed, restricted, or made unavailable in any territory. Similarly, Aurelius content remained actively streaming on the four FAST channel sublicensee platforms operated by Brindoval Channel Networks, BrightLoop Media, Velvet Stream Partners, and Pacific Lantern Digital.
New viewership data obtained during the final days of the data collection period indicates that the infringement is ongoing beyond the January 31, 2026 measurement cutoff used for the revenue attribution analysis. Streams of Aurelius content continued during February 2026 at rates consistent with the sustained viewing patterns observed throughout the Infringement Period, and additional revenue continued to accrue to StreamNow and its sublicensees.
CipherTrace is prepared to update its forensic analysis to capture continued infringement through the date of any injunctive relief, takedown, or other cessation of infringing activity. This capability will be important in connection with any motion for a temporary restraining order or preliminary injunction, as well as for calculating ongoing damages through the date of resolution.
X. KEY EXHIBITS AND SUPPORTING MATERIALS
A. List of Exhibits Prepared by CipherTrace
CipherTrace has prepared the following exhibits in connection with its forensic analysis, each of which is available for review by the engagement team and for inclusion in the pre-suit demand and anticipated litigation filings:
Exhibit A: Complete list of all 217 Aurelius-owned audiovisual titles confirmed present on the StreamNow platform, with individual fingerprint match confidence scores, content ingestion dates, and tier availability designations (SVOD, AVOD, or both) for each title. The exhibit is organized by content category (feature films; television series with individual episode listings) and includes title, year of release, running time, and Aurelius copyright registration numbers where available.
Exhibit B: Content ingestion timeline chart illustrating the batch upload dates for the Aurelius content catalog, including the initial batch ingestion (approximately March 28 – April 5, 2024, covering 197 titles) and the secondary batch ingestion (approximately May 15 – June 30, 2024, covering 20 titles). The chart provides a visual representation of the relationship between the ingestion timeline and the date of the purported Content Distribution Agreement between MDD and StreamNow.
Exhibit C: Geographic distribution map showing the availability of Aurelius titles across StreamNow's fourteen operating territories. The map identifies each territory and confirms that no geographic restrictions were applied to the Aurelius content.
Exhibit D: Viewership data tables presenting monthly stream counts, unique viewer counts, and aggregate viewing hours for Aurelius titles for each month of the Infringement Period (April 2024 through January 2026). The tables include breakdowns by platform tier (SVOD and AVOD) and by territory where data is available.
Exhibit E: Revenue attribution model documentation, including the detailed methodology, underlying assumptions, data sources, and step-by-step calculations for the subscription revenue attribution ($22.4 million), advertising revenue attribution ($9.7 million), and sublicensing fee attribution ($6.5 million). The exhibit includes sensitivity analyses illustrating the impact of alternative assumptions on the revenue attribution figures.
Exhibit F: FAST channel sublicensee content identification results, presenting fingerprint matching results for each of the four sublicensees (Brindoval Channel Networks, BrightLoop Media, Velvet Stream Partners, and Pacific Lantern Digital), with complete title lists identifying the Aurelius titles confirmed present on each sublicensee's FAST channel or channels.
Exhibit G: Screenshots and platform metadata captures documenting StreamNow's editorial curation of Aurelius titles, including evidence of placement in "Featured," "Trending," and "Staff Picks" editorial collections, recommendation algorithm data showing active promotion of Aurelius titles to StreamNow users, and display of Aurelius branding and production credits on the StreamNow platform.
Exhibit H: Chain-of-custody documentation for all reference materials received from Aurelius Media Americas, Inc. and for all data sets extracted during the forensic analysis, including timestamps, hash values, and custodian records.
B. Expert Report Availability
Dr. Nathan Frey is prepared to issue a formal expert report suitable for filing in the United States District Court for the Central District of California, in compliance with Federal Rule of Civil Procedure 26(a)(2)(B). Dr. Frey is further prepared to provide testimony in support of a motion for a temporary restraining order and/or preliminary injunction and to testify at trial, if required.
The estimated completion date for the formal expert report is April 2026, subject to adjustments based on the litigation timeline and any additional data collection or analysis requested by the engagement team or required by developments in the case.
XI. CONCLUSIONS
Based on the forensic analysis conducted by CipherTrace Analytics, LLC, the following principal conclusions are supported:
1. CipherTrace's content fingerprinting analysis confirms that all 217 Aurelius-owned audiovisual works — comprising 142 feature films and 75 television series encompassing 1,038 individual episodes — are present on the StreamNow platform and have been available for streaming since approximately April 1, 2024, a period of at least twenty-two months.
2. The content was ingested into the StreamNow platform shortly after the March 15, 2024 date of the purported Content Distribution Agreement between Meridian Digital Distributors, LLC (Franklin Ogilvie, sole member/manager; California Secretary of State File No. 202115729430; business address: 8912 Burton Way, Suite 200, Beverly Hills, California 90211) and StreamNow Holdings, Inc. (Delaware File No. 7291843; headquarters: 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010).
3. StreamNow actively curated, editorially promoted, and commercially monetized the Aurelius content across its subscription (SVOD), advertising-supported (AVOD), and sublicensing revenue channels, generating an estimated total of $38.6 million in attributable revenue during the Infringement Period.
4. The Aurelius content was distributed to viewers in all fourteen countries in which StreamNow operates and was sublicensed to four downstream FAST channel operators — Brindoval Channel Networks, Inc.; BrightLoop Media, LLC; Velvet Stream Partners, LP; and Pacific Lantern Digital Pty Ltd — without authorization from Aurelius.
5. StreamNow's active curation, editorial promotion, tier placement, geographic distribution, and downstream sublicensing of the Aurelius content demonstrates that StreamNow functioned as a commercial content distributor, not a passive hosting service, and accordingly does not qualify for DMCA § 512 safe harbor protection.
6. The infringement is ongoing as of March 1, 2026, with all 217 titles remaining available on the StreamNow platform and on the four FAST channel sublicensee platforms.
7. These findings provide a strong technical and evidentiary foundation for the pre-suit demand and anticipated litigation against StreamNow Holdings, Inc. and potentially against MDD, Franklin Ogilvie, and the FAST channel sublicensees, as may be determined by the engagement team in consultation with the client.
XII. PREPARATION AND DISTRIBUTION
Prepared by:
Omar Siddiqui, Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200
Email: osiddiqui@calderwoodharkness.com
Reviewed by:
Wendy Schultz, Senior Associate Calderwood & Harkness LLP
Based on:
CipherTrace Analytics, LLC preliminary findings report delivered to Calderwood & Harkness LLP on March 3, 2026; supporting data sets and exhibits provided by CipherTrace under the terms of the expert retention letter dated February 18, 2026.
Matter No.: 1017-00003
Distribution:
Engagement Team:
• Marcus Delgado, Partner, Calderwood & Harkness LLP
• Catherine Bloom, Partner, Calderwood & Harkness LLP
• Wendy Schultz, Senior Associate, Calderwood & Harkness LLP
• Omar Siddiqui, Associate, Calderwood & Harkness LLP
Client Representatives:
• Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC
• Lena Kowalski, Head of Digital Rights Enforcement, Aurelius Media Americas, Inc.
ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL This memorandum constitutes attorney work product prepared in anticipation of litigation and is protected by the attorney-client privilege and work product doctrine. Any unauthorized review, use, disclosure, or distribution is strictly prohibited. If you have received this document in error, please notify the sender immediately and destroy all copies.
Revenue Stream | Attributed Amount
Subscription revenue (SVOD) | $22,400,000
Advertising revenue (AVOD) | $9,700,000
Sublicensing fees (FAST channels) | $6,500,000
Total Attributable Revenue | $38,600,000