PRIVILEGED & CONFIDENTIAL

PRIVILEGED & CONFIDENTIAL
CALDERWOOD & HARKNESS LLP Attorneys at Law
1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8200 Facsimile: (310) 556-8201
600 Lexington Avenue New York, New York 10022 Telephone: (212) 848-7300 Facsimile: (212) 848-7301
Catherine Bloom Partner, intellectual Property Direct Dial: (310) 556-8247 Direct Fax: (310) 556-8290
Email: cbloom@calderwoodharkness.com
March 1, 2026
VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED AND VIA EMAIL (claims@fortbridgespecialty.com)
Fortbridge Specialty Insurance Company Claims Department — Notice of Claim 280 Trumbull Street Hartford, CT 06103
Re: Notice of Claim Under Policy No. FSI-ML-2024-07821 Insured: Aurelius Global Media Group PLC (Companies House Reg. No. 08724561) Matter: Pre-Suit Copyright Enforcement Action — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al. Calderwood & Harkness LLP Matter No.: 1017-00003
Dear Sir or Madam:
I. PURPOSE AND BASIS OF NOTICE
This firm represents Aurelius Global Media Group PLC ("Aurelius" or "AGMG"), a public limited company incorporated in England and Wales (Companies House Registration No. 08724561), with its principal headquarters at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius conducts its United States operations through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. Aurelius is listed on the London Stock Exchange's Alternative Investment Market (AIM: AGLM) and reported fiscal year 2025 revenue of approximately £1.87 billion (approximately $2.36 billion USD at prevailing exchange rates).
Aurelius is a named insured under that certain Media Liability / Intellectual Property Enforcement Policy issued by Fortbridge Specialty Insurance Company, bearing Policy No. FSI-ML-2024-07821 (the "Policy"). The Policy provides coverage for media perils and intellectual property enforcement with limits of liability of $25,000,000 per occurrence and $50,000,000 in the aggregate.
This letter constitutes Aurelius's formal notice of claim and tender under the Policy in connection with Aurelius's copyright enforcement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and related parties, as more fully described herein. This notice is being provided pursuant to the Policy's notice provisions and in accordance with all applicable requirements for the timely tender of claims. Aurelius respectfully requests that Fortbridge acknowledge coverage, assign a dedicated claims adjuster, and advise of any reservation of rights or requests for additional information in accordance with the procedures set forth below.
II. IDENTIFICATION OF THE INSURED
The insured tendering this claim is identified as follows:
Full Legal Name: Aurelius Global Media Group PLC
Entity Type: Public limited company, incorporated under the laws of England and Wales
Companies House Registration No.: 08724561
Principal Headquarters: 45 Clarewood Place, London W1K 6TH, United Kingdom
U.S. Subsidiary: Aurelius Media Americas, Inc., 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067
Chief Executive Officer: Sir Alistair Pemberton
General Counsel and Primary Client Contact: Fiona Hartwell
Industry: Media, entertainment, and e-commerce
Content Library: In excess of 4,200 film and television titles
Auditors: Whitmore & Pryce LLP, 25 Old Broad Street, London EC2N 1HQ, United Kingdom
Aurelius is one of the United Kingdom's largest independent media companies, with a diversified portfolio spanning theatrical film production and distribution, television programming, digital content licensing, merchandise, and e-commerce. Aurelius's extensive library of intellectual property is central to its business and represents a significant portion of its enterprise value. Through its U.S. subsidiary, Aurelius Media Americas, Inc., Aurelius licenses and distributes content across North America and oversees its relationships with U.S.-based digital platforms, broadcasters, and distributors.
III. POLICY INFORMATION
The relevant insurance policy information is as follows:
Policy Number: FSI-ML-2024-07821
Insurer: Fortbridge Specialty Insurance Company
Coverage Type: Media Liability / Intellectual Property Enforcement
Per Occurrence Limit of Liability: $25,000,000
Aggregate Limit of Liability: $50,000,000
Insurance Broker of Record: Calder & Whitfield Insurance Brokers Ltd., 71 Fenchurch Street, London EC3M 4BS, United Kingdom
Aurelius respectfully requests that Fortbridge direct any and all correspondence regarding this claim to both Calderwood & Harkness LLP, as Aurelius's designated outside counsel of record, and to Calder & Whitfield Insurance Brokers Ltd., as Aurelius's broker of record for the Policy. Specific contact information and correspondence instructions are set forth in Section XIII of this letter.
IV. DESCRIPTION OF THE CLAIM — PARTIES INVOLVED
A. Prospective Defendant: StreamNow Holdings, Inc.
Full Legal Name: StreamNow Holdings, Inc.
Entity Type: Delaware corporation (Delaware Division of Corporations File No. 7291843)
Principal Headquarters: 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010
Registered Agent (Delaware): Capitol Registered Agents, Inc., 1209 Orange Street, Wilmington, Delaware 19801
Industry: Streaming media aggregation and distribution
Year Founded: 2019
Ownership Status: Privately held; majority-owned (approximately 62% on a fully diluted basis) by Pinnacle Ventures Fund III, LP (101 California Street, Suite 3500, San Francisco, California 94111), which led a $145 million Series C financing round that closed in June 2022
Estimated FY2025 Revenue: Approximately $312 million
StreamNow operates as a so-called "super-aggregator" platform, offering subscribers access to a consolidated library of licensed film and television content sourced from multiple studios, distributors, and independent content providers. StreamNow's platform is available in the United States, Canada, Australia, and a number of additional international territories, and offers both subscription-based (SVOD) and advertising-supported (AVOD) viewing tiers.
The key officers and representatives of StreamNow relevant to this matter are as follows:
•  Derek Calloway — Chief Executive Officer and Co-Founder
•  Priya Menon — Chief Operating Officer and Co-Founder
•  Tobias Rennert — General Counsel
•  Sandra Yee — Vice President, Content Acquisition
StreamNow is represented by outside counsel Grantham Roth & Pearce LLP, 555 South Flower Street, Suite 4200, Los Angeles, California 90071. The lead partner on behalf of StreamNow is Victoria Langford.
B. Additional Prospective Defendant: Meridian Digital Distributors, LLC
Full Legal Name: Meridian Digital Distributors, LLC ("MDD")
Entity Type: California limited liability company (California Secretary of State File No. 202115729430)
Registered Address: 8912 Burton Way, Suite 200, Beverly Hills, California 90211
Principal: Franklin Ogilvie, Sole Member and Manager
Franklin Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc. Mr. Ogilvie was employed by AMA from approximately 2017 through June 30, 2021. His employment was terminated following an internal investigation conducted by Aurelius's compliance and legal departments, which revealed that Mr. Ogilvie had engaged in unauthorized access to Aurelius's content management systems and proprietary licensing databases. At the time of his separation, Mr. Ogilvie executed a Separation and Release Agreement dated June 30, 2021, which included, among other restrictive covenants, non-competition and non-solicitation provisions, as well as an explicit prohibition on the use, reproduction, distribution, or exploitation of any Aurelius intellectual property, including but not limited to Aurelius's content library, licensing data, and proprietary metadata.
MDD was incorporated in late 2021, shortly after the termination of Mr. Ogilvie's employment. Aurelius's records confirm that MDD is not, and has never been, an authorized distributor, licensee, sublicensee, or agent of Aurelius with respect to any Aurelius-owned content, and at no time has Aurelius granted MDD any rights in or to any audiovisual works in its catalog.
C. Additional Prospective Defendants: FAST Channel Sublicensees
In addition to StreamNow and MDD, Aurelius anticipates asserting claims against four third-party Free Ad-Supported Streaming Television ("FAST") channel operators to whom StreamNow sublicensed bundles of content that included Aurelius-owned titles. These entities are as follows:
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
Each of these four entities received and made available to viewers Aurelius-owned audiovisual works that were sublicensed by StreamNow without any authorization from Aurelius. Aurelius is continuing its investigation into the scope of distribution and viewership attributable to each of these sublicensees and will supplement this notice with additional details as they become available.
V. NATURE OF THE CLAIM — FACTUAL BACKGROUND
Aurelius alleges that StreamNow has, without authorization, reproduced, distributed, and publicly performed a substantial catalog of Aurelius-owned audiovisual works through the StreamNow platform and through sublicensed FAST channels. The scope, duration, and commercial scale of the infringement are summarized below.
Works at Issue. The infringement involves a total of 217 individual titles owned by Aurelius, comprising 142 feature films and 75 television series, the latter encompassing a combined total of 1,038 individual episodes. These titles represent some of the most commercially significant properties in Aurelius's content library, including:
•  The "Meridian" franchise: Six feature films with a combined worldwide theatrical box office gross of approximately $1.43 billion. The Meridian franchise is one of the most commercially successful action-adventure film series of the last decade and is a cornerstone of Aurelius's theatrical, home entertainment, and digital licensing revenues.
•  The "Iron Compass" series: Four seasons comprising a total of 48 episodes. Iron Compass is Aurelius's highest-rated original television series, averaging approximately 9.2 million viewers per episode in the United Kingdom during its original broadcast run, and has been a major draw for digital platforms that have licensed the series in secondary windows.
•  The "Thornfield" period drama catalog: Twelve titles, including feature films and limited series, which have collectively received seven BAFTA awards. The Thornfield catalog represents a prestige portfolio that commands premium licensing rates in both domestic and international markets.
Period of Infringement. Based on Aurelius's investigation to date, including digital forensic analysis conducted by CipherTrace Analytics, LLC (discussed in Section IX below), the unauthorized exploitation of Aurelius content through the StreamNow platform and its sublicensed channels commenced on or about April 1, 2024 and continued through at least January 31, 2026, a period of approximately twenty-two (22) months. During this period, the 217 infringing titles were available for streaming to subscribers and AVOD viewers in the United States, Canada, Australia, and eleven (11) additional territories, for a total of fourteen (14) countries.
StreamNow's Distribution Activities. StreamNow ingested the 217 Aurelius titles into its platform content library, assigned metadata and categorization designations, and made the titles available for on-demand streaming to its subscriber base across multiple pricing tiers, including both its premium subscription (SVOD) tier and its ad-supported (AVOD) tier. In addition, StreamNow sublicensed bundles of content — including Aurelius-owned titles — to the four FAST channel operators identified in Section IV.C above, thereby extending the unauthorized distribution of Aurelius's works to additional audiences and platforms.
StreamNow's Claimed Authority. When confronted with Aurelius's informal inquiry in November 2025 (as described in Section VI below), StreamNow, through its Vice President of Content Acquisition, Sandra Yee, claimed to have obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC, purportedly pursuant to a "Content Distribution Agreement" allegedly executed on or about March 15, 2024. According to StreamNow's representations, this agreement purported to cover in excess of 350 titles, including the 217 Aurelius-owned titles at issue.
Absence of Any Aurelius Authorization. Aurelius's records confirm — and Aurelius states categorically — that it has never granted MDD, Franklin Ogilvie, or any affiliate, agent, or assignee of either party any license, sublicense, or distribution authority over any content in the Aurelius catalog. MDD has never been an authorized distributor of Aurelius content under any circumstances. Furthermore, Aurelius has never executed or authorized any license agreement with StreamNow, nor has Aurelius authorized any intermediary to sublicense Aurelius content to StreamNow or any other party on Aurelius's behalf. The purported Content Distribution Agreement between MDD and StreamNow is, as to Aurelius's rights, wholly unauthorized and without any lawful basis.
VI. DISCOVERY AND INVESTIGATION TIMELINE
The following timeline summarizes the key events in Aurelius's discovery and investigation of the infringement that forms the basis of this claim:
October 15, 2025: Lena Kowalski, Head of Digital Rights Enforcement for Aurelius, discovered multiple Aurelius-owned titles streaming on the StreamNow platform during routine platform monitoring. Ms. Kowalski identified titles from the Meridian franchise and the Iron Compass series, among others, and flagged the unauthorized availability for internal review.
October 22, 2025: Ms. Kowalski escalated her findings to Fiona Hartwell, General Counsel of Aurelius. Ms. Hartwell authorized the commencement of a comprehensive internal investigation to determine the scope of unauthorized distribution and the basis, if any, for StreamNow's exploitation of Aurelius content.
November 3, 2025: Sandra Yee, Vice President of Content Acquisition at StreamNow, responded to an informal inquiry from Raj Anantharam, Senior Vice President of Content Licensing & Distribution at Aurelius, via email. In her response, Ms. Yee asserted that StreamNow had acquired rights to the Aurelius titles through a sublicense from Meridian Digital Distributors, LLC, but did not provide copies of the underlying agreements or any documentation establishing the chain of rights.
November 18, 2025: Aurelius engaged Bexley Marsh Solicitors LLP, 14 Bedford Row, London WC1R 4ED, United Kingdom, as its outside UK counsel to conduct a preliminary legal assessment of potential claims arising from the unauthorized exploitation, including an analysis of applicable UK, US, and international copyright frameworks.
December 5, 2025: Following its preliminary assessment, Bexley Marsh recommended the engagement of U.S. counsel to evaluate and pursue federal copyright infringement claims under United States law, given that the primary infringing activities and principal infringers are located in the United States.
January 8, 2026: Aurelius contacted Calderwood & Harkness LLP regarding potential representation in connection with the enforcement action.
January 15, 2026: An initial consultation was held between Marcus Delgado, Partner at Calderwood & Harkness LLP, and Fiona Hartwell, General Counsel of Aurelius, during which the factual background, potential legal theories, and preliminary enforcement strategy were discussed.
January 22, 2026: Lexington IP Services, Inc. (1625 I Street NW, Suite 400, Washington, DC 20006; contact: Marissa Chung) completed a comprehensive U.S. Copyright Office registration verification and chain-of-title search for all 217 titles at issue. The results of this search are summarized in Section VIII of this letter.
February 12, 2026: Calderwood & Harkness LLP's engagement was formally opened under Matter No. 1017-00003.
February 14, 2026: An initial retainer in the amount of $150,000 was received from Aurelius.
VII. LEGAL CLAIMS ASSERTED AND TO BE ASSERTED
Based on the facts set forth herein and Aurelius's investigation to date, Aurelius anticipates asserting the following legal claims:
1.  Federal Copyright Infringement under 17 U.S.C. §§ 106 and 501 — against StreamNow Holdings, Inc. Aurelius will assert that StreamNow engaged in the unauthorized reproduction, distribution, and public performance of Aurelius-owned audiovisual works in violation of Aurelius's exclusive rights under 17 U.S.C. § 106(1), (3), and (4).
2.  Contributory Copyright Infringement — against Meridian Digital Distributors, LLC and Franklin Ogilvie individually. Aurelius will assert that MDD and Ogilvie had knowledge of the infringing activity and materially contributed to it by providing StreamNow with access to Aurelius's content under a fraudulent sublicense, thereby enabling StreamNow's infringing reproduction, distribution, and public performance.
3.  Inducement of Copyright Infringement — against Meridian Digital Distributors, LLC and Franklin Ogilvie individually. Aurelius will assert that MDD and Ogilvie acted with the intent to cause copyright infringement by affirmatively inducing StreamNow to infringe Aurelius's copyrights through the creation and execution of the fraudulent Content Distribution Agreement and the supply of Aurelius content for ingestion into StreamNow's platform.
4.  Unfair Business Practices under California Business and Professions Code § 17200 — against StreamNow Holdings, Inc. Aurelius will assert that StreamNow's unauthorized exploitation of Aurelius content constitutes an unlawful, unfair, or fraudulent business practice under California law.
5.  Tortious Interference with Prospective Economic Advantage — against StreamNow Holdings, Inc. Aurelius will assert that StreamNow's unauthorized exploitation of Aurelius content has interfered with Aurelius's existing and prospective licensing relationships with authorized distributors and platforms, resulting in measurable economic harm.
6.  Potential Claims Against Franklin Ogilvie and MDD for Breach of Separation Agreement and Fraud. Aurelius is evaluating additional claims against Franklin Ogilvie and MDD for breach of the Separation and Release Agreement dated June 30, 2021, and for fraud in connection with the creation and execution of the purported Content Distribution Agreement with StreamNow. Aurelius reserves all rights with respect to these claims and will supplement this notice as its investigation continues.
Proposed Forum. Aurelius intends to file its complaint, if litigation becomes necessary, in the United States District Court for the Central District of California, Los Angeles Division, which has subject matter jurisdiction over federal copyright claims under 28 U.S.C. §§ 1331 and 1338(a), and where personal jurisdiction and venue are proper as to StreamNow and MDD.
DMCA Safe Harbor Inapplicability. It is Aurelius's position that StreamNow does not qualify for the safe harbor protections of the Digital Millennium Copyright Act, 17 U.S.C. § 512. StreamNow is not a passive conduit or hosting service; rather, it actively curates, licenses (or purports to license), and monetizes content on its platform. StreamNow exercises editorial control over catalog selection, pricing tiers, geographic availability, and promotional placement. Accordingly, StreamNow's activities fall outside the scope of § 512's safe harbor provisions.
VIII. COPYRIGHT REGISTRATION STATUS
The copyright registration status of the 217 titles at issue has been verified through a comprehensive U.S. Copyright Office records search conducted by Lexington IP Services, Inc. and completed on January 22, 2026. The results are as follows:
•  189 titles possess valid, timely U.S. copyright registrations. These registrations were made within three (3) months of the date of first publication of the respective works or, in any event, prior to the commencement of the infringing activity on or about April 1, 2024. As a result, these 189 titles are eligible for the recovery of statutory damages under 17 U.S.C. § 504(c) and attorneys' fees under 17 U.S.C. § 505.
•  28 titles possess U.S. copyright registrations that post-date the commencement of the infringement. These registrations were filed between May 2024 and October 2025. Because these registrations were not obtained prior to the commencement of infringement (and were not made within three months of first publication), recovery for these 28 titles is limited to actual damages and the infringer's profits attributable to the infringement, pursuant to 17 U.S.C. § 504(a) and (b). These titles are not eligible for statutory damages or an award of attorneys' fees.
A detailed Copyright Registration Summary Report prepared by Lexington IP Services, Inc. is enclosed with this letter as a referenced enclosure.
IX. ESTIMATED DAMAGES
Aurelius has retained the following expert consultants to assess the scope and quantum of damages resulting from the infringement:
CipherTrace Analytics, LLC 2700 Sand Hill Road, Suite 130 Menlo Park, California 94025 Engagement Lead: Dr. Nathan Frey
CipherTrace has been retained as a digital forensics expert to perform content fingerprinting, metadata extraction, and revenue attribution analysis. CipherTrace's analysis is designed to identify and quantify the specific instances of unauthorized reproduction, distribution, and streaming of Aurelius content across the StreamNow platform and its sublicensed channels, and to attribute revenue generated by StreamNow and its sublicensees to the exploitation of Aurelius-owned works.
Hargrove Economic Consulting Group, LLC 350 South Grand Avenue, Suite 2800 Los Angeles, California 90071 Engagement Lead: Dr. Elena Vasquez
Hargrove has been retained as a damages expert to develop and present a comprehensive damages model incorporating both actual damages (including lost licensing revenue) and the infringer's profits attributable to the unauthorized exploitation of Aurelius content.
Based on the preliminary analysis conducted by CipherTrace and Hargrove, Aurelius's estimated damages are summarized as follows:
StreamNow's Estimated Revenue Attributable to Aurelius Content (April 2024 – January 2026):
Aurelius's Lost Licensing Revenue: Based on comparable arm's-length license agreements for content of similar quality, scope, and commercial value in the relevant territories and time periods, the estimated fair market value of a license for the 217 titles at issue is approximately $14,200,000.
Statutory Damages Alternative: For the 189 timely-registered works, Aurelius may elect to recover statutory damages in lieu of actual damages and profits. Given the willful nature of the infringement — StreamNow's exploitation of content obtained through a fraudulent intermediary, without any direct authorization from the rights holder — Aurelius contends that the maximum statutory damages award of $150,000 per work is appropriate. The aggregate statutory damages for 217 works at the maximum rate would total $32,550,000. However, Aurelius notes that statutory damages are available only for the 189 timely-registered works, and the actual statutory damages election will be refined as the case develops.
Preliminary Net Recoverable Damages Estimate: Hargrove Economic Consulting Group has prepared a preliminary estimate of net recoverable damages, combining actual damages (lost licensing revenue) with the infringer's profits and apportioning the two categories to avoid double-counting, in accordance with the framework established by 17 U.S.C. § 504(b). Hargrove's preliminary estimate of net recoverable damages is $41,300,000.
Attorneys' Fees and Costs: In addition to the foregoing damages, Aurelius anticipates seeking an award of attorneys' fees and litigation costs pursuant to 17 U.S.C. § 505 with respect to the 189 timely-registered works. The amount of such fees and costs will be determined as the enforcement action progresses.
X. COVERAGE REQUESTED
Aurelius hereby requests that Fortbridge Specialty Insurance Company acknowledge coverage under Policy No. FSI-ML-2024-07821 for the costs of the enforcement action described in this letter. Specifically, Aurelius requests coverage for the following categories of expenses:
Outside Counsel Fees. Calderwood & Harkness LLP is serving as Aurelius's outside counsel for this matter. The hourly billing rates for the members of the Calderwood & Harkness team assigned to this matter are as follows:
The estimated budget for the pre-suit phase of this matter, including pre-suit investigation, preparation and service of demand letters, and initial settlement negotiations, is $485,000.
Expert Costs. The estimated costs for the expert consultants engaged in connection with this matter are as follows:
Anticipated Litigation Costs. If the pre-suit demand does not result in a satisfactory resolution, Aurelius intends to file a complaint and seek injunctive relief in the United States District Court for the Central District of California, with a target filing date in or about June 2026. The costs of litigation — including filing fees, service of process, discovery, depositions, expert testimony, motion practice, and trial preparation — will increase substantially beyond the pre-suit phase estimates set forth above. Aurelius will provide Fortbridge with updated cost estimates and budget projections as the matter progresses and as the scope of litigation becomes clearer.
Aurelius respectfully requests that Fortbridge take the following actions in response to this notice:
1.  Confirm that the enforcement action described herein is covered under Policy No. FSI-ML-2024-07821;
2.  Assign a dedicated claims adjuster or claims handler to this matter;
3.  Advise Aurelius and its counsel of any reservation of rights, coverage defenses, or additional information that Fortbridge may require to complete its evaluation of this claim; and
4.  Provide the foregoing confirmation and any reservation of rights in writing within fifteen (15) business days of receipt of this notice.
XI. ANTICIPATED TIMELINE AND UPCOMING MILESTONES
Aurelius provides the following anticipated timeline and upcoming milestones for the enforcement action, subject to revision as circumstances develop:
March 2026 (target): Service of formal cease-and-desist and pre-suit demand letters on StreamNow Holdings, Inc., Meridian Digital Distributors, LLC / Franklin Ogilvie, and the four FAST channel sublicensees identified in Section IV.C above.
April – May 2026 (target): Settlement negotiation window. Aurelius intends to provide StreamNow and MDD with a thirty (30)-day response period following service of the demand letter, during which the parties may engage in good-faith settlement discussions.
June 2026 (contingent): If a satisfactory settlement is not reached during the negotiation period, Aurelius intends to file a complaint in the United States District Court for the Central District of California and to seek a temporary restraining order and/or preliminary injunction to halt the ongoing unauthorized exploitation of Aurelius's content.
Aurelius will keep Fortbridge informed of all material developments in this matter on a timely basis and will supplement this notice as the enforcement action progresses.
XII. OUTSIDE COUNSEL AND EXPERT TEAM
The following counsel and expert consultants are engaged on behalf of Aurelius in connection with this matter:
Outside U.S. IP Counsel — Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067
•  Marcus Delgado, Partner (Responsible Partner)
•  Catherine Bloom, Partner (Billing Partner)
•  Wendy Schultz, Senior Associate (Lead Associate)
•  Omar Siddiqui, Associate
Outside UK IP Counsel — Bexley Marsh Solicitors LLP 14 Bedford Row London WC1R 4ED, United Kingdom
Digital Forensics Expert — CipherTrace Analytics, LLC 2700 Sand Hill Road, Suite 130 Menlo Park, California 94025 Engagement Lead: Dr. Nathan Frey
Copyright Registration Searches — Lexington IP Services, Inc. 1625 I Street NW, Suite 400 Washington, DC 20006 Contact: Marissa Chung
Damages Expert — Hargrove Economic Consulting Group, LLC 350 South Grand Avenue, Suite 2800 Los Angeles, California 90071 Engagement Lead: Dr. Elena Vasquez
XIII. BROKER INFORMATION AND CORRESPONDENCE INSTRUCTIONS
The insurance broker of record for the Policy is:
Calder & Whitfield Insurance Brokers Ltd. 71 Fenchurch Street London EC3M 4BS United Kingdom
Aurelius respectfully requests that Fortbridge copy Calder & Whitfield Insurance Brokers Ltd. on all correspondence regarding this claim.
In addition, all correspondence regarding this claim should be directed to the following individuals:
Catherine Bloom Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8247
Email: cbloom@calderwoodharkness.com
Fiona Hartwell General Counsel Aurelius Global Media Group PLC 45 Clarewood Place London W1K 6TH United Kingdom
Email: f.hartwell@aureliusmedia.com
XIV. RESERVATION OF RIGHTS AND REQUEST FOR ADDITIONAL INFORMATION
Aurelius expressly reserves all of its rights under Policy No. FSI-ML-2024-07821, including but not limited to coverage for defense costs, outside counsel fees, expert fees, litigation expenses, and any other amounts payable in connection with the enforcement action described herein. Nothing in this notice shall be construed as a waiver or limitation of any right, claim, or entitlement of Aurelius under the Policy or otherwise.
Aurelius will promptly provide any additional documentation, information, or supporting materials that Fortbridge may reasonably require in order to evaluate and process this claim. Aurelius requests that Fortbridge acknowledge receipt of this notice and respond with confirmation of coverage, assignment of a claims handler, and any requests for supplemental information within fifteen (15) business days of receipt.
XV. DOCUMENT PRESERVATION
Aurelius respectfully requests that Fortbridge Specialty Insurance Company immediately preserve all documents, underwriting files, communications (including internal memoranda and correspondence), notes, and records of any kind relating to Policy No. FSI-ML-2024-07821 and to this claim. This request encompasses all materials in Fortbridge's possession, custody, or control, whether maintained in physical or electronic form, including but not limited to the complete underwriting file, policy application materials, endorsements, binders, correspondence with the broker of record, internal claims notes, and any communications with reinsurers.
We appreciate your prompt attention to this matter. We stand ready to discuss this claim at Fortbridge's convenience and would welcome the opportunity to arrange a call or meeting with the Calderwood & Harkness engagement team and/or Aurelius's General Counsel, Fiona Hartwell, to provide any additional background or respond to questions from the assigned claims handler. Please do not hesitate to contact the undersigned directly at the telephone number and email address listed above.
We look forward to Fortbridge's timely acknowledgment and response.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Catherine Bloom Partner, intellectual Property 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 556-8247
Email: cbloom@calderwoodharkness.com
cc: (via email and first-class mail)
Fiona Hartwell, General Counsel, Aurelius Global Media Group PLC Sir Alistair Pemberton, Chief Executive Officer, Aurelius Global Media Group PLC Marcus Delgado, Partner, Calderwood & Harkness LLP Calder & Whitfield Insurance Brokers Ltd. (Broker of Record)
Enclosures:
1.  Copy of Policy No. FSI-ML-2024-07821, Declarations Page
2.  Calderwood & Harkness LLP Engagement Letter dated February 12, 2026
3.  Copyright Registration Summary Report (Lexington IP Services, Inc., January 22, 2026)
Revenue Category | Estimated Amount
Subscription revenue (SVOD tier) allocable to Aurelius titles | $22,400,000
Advertising revenue (AVOD tier) allocable to Aurelius titles | $9,700,000
Sublicensing fees received from FAST channel operators | $6,500,000
Total attributable revenue | $38,600,000
Attorney | Role | Hourly Rate
Marcus Delgado, Partner | Responsible Partner | $1,350/hr
Catherine Bloom, Partner | Billing Partner | $1,275/hr
Wendy Schultz, Senior Associate | Lead Associate | $895/hr
Omar Siddiqui, Associate | Associate | $725/hr
Expert | Scope | Estimated Cost
CipherTrace Analytics, LLC | Digital forensic analysis, content fingerprinting, revenue attribution | $175,000
Lexington IP Services, Inc. | Copyright registration searches and chain-of-title verification | $28,500
Hargrove Economic Consulting Group, LLC | Preliminary damages model development | $95,000
Total estimated expert costs | $298,500