1017-00003 · Aurelius Global Media Group · Legal Analysis & Strategy

jurisdictional-venue-analysis.docx DOCUMENT Litigation

29 / 37 ← → ✕

Contract analysis Extract to table

MEMORANDUM

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT

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

FROM: Omar Siddiqui, Associate

DATE: February 27, 2026

RE: Jurisdictional & Venue Analysis — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al.

MATTER NO.: 1017-00003

CLIENT: Aurelius Global Media Group PLC

This memorandum is protected by the attorney-client privilege, the work product doctrine, and all other applicable privileges. It is intended solely for the use of the individuals identified above and other members of the engagement team. Do not distribute, copy, or disclose this memorandum or its contents without the express written authorization of the undersigned or a partner on this matter. Any inadvertent disclosure does not constitute a waiver of any applicable privilege.

I. EXECUTIVE SUMMARY

You have asked me to analyze whether the United States District Court for the Central District of California, Los Angeles Division, is the proper forum for Aurelius Global Media Group PLC's ("Aurelius") anticipated copyright infringement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie (collectively, "Defendants"). This memorandum examines federal subject matter jurisdiction, personal jurisdiction over each prospective defendant, and venue, and addresses potential jurisdictional challenges the Defendants may raise.

Conclusion. Based on the analysis set forth below, the Central District of California, Los Angeles Division, is the appropriate forum for this action, and I recommend filing in that court. Federal subject matter jurisdiction is firmly established under 28 U.S.C. § 1338(a), which grants federal district courts original and exclusive jurisdiction over civil actions arising under the Copyright Act, 17 U.S.C. §§ 106, 501. Supplemental jurisdiction under 28 U.S.C. § 1367 covers the state-law unfair competition claim brought under California Business and Professions Code § 17200 and the tortious interference with prospective economic advantage claim, as both arise from the same common nucleus of operative fact as the federal copyright claims. Diversity jurisdiction under 28 U.S.C. § 1332(a)(2) provides an alternative basis if Aurelius, as a foreign entity, is the sole named plaintiff. Personal jurisdiction — both general and specific — exists over all three prospective defendants: StreamNow is headquartered in Los Angeles; MDD is a California LLC with its registered address in Beverly Hills; and Ogilvie is a California domiciliary who resides in the Beverly Hills area. Venue is proper under the copyright-specific venue statute, 28 U.S.C. § 1400(a), and alternatively under the general venue statute, 28 U.S.C. § 1391(b)(1) and (b)(2). No viable jurisdictional or venue challenge is anticipated from any defendant.

II. FACTUAL BACKGROUND RELEVANT TO JURISDICTION AND VENUE

The following factual summary is drawn from client documents, internal investigation materials, the Lexington IP Services copyright registration search completed January 22, 2026, and the preliminary findings of the CipherTrace forensic analysis. This summary is limited to facts bearing on jurisdiction and venue; a comprehensive factual recitation will be included in the forthcoming draft complaint and the accompanying statement of facts memorandum.

A. The Plaintiff — Aurelius Global Media Group PLC

Aurelius Global Media Group PLC is a United Kingdom public limited company registered with Companies House under Registration Number 08724561. Its corporate headquarters are located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Exchange under the Alternative Investment Market (AIM: AGLM), and its American Depositary Receipts ("ADRs") are traded over-the-counter in the United States.

Aurelius conducts its U.S. operations through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), which maintains its principal offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA is responsible for content licensing, distribution, and production activities within North America and serves as Aurelius's primary point of contact with U.S.-based platform partners, distributors, and talent agencies.

For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). The company's content library consists of more than 4,200 titles spanning film, television, and digital media. Of these, 217 titles are at issue in this matter: 142 feature films and 75 television series comprising a total of 1,038 individual episodes. These works represent a significant and commercially valuable portion of Aurelius's catalog.

As a threshold matter, I note that Aurelius may file this action as plaintiff directly, or alternatively through AMA. Both entities possess standing as copyright holders with respect to the works at issue. The chain-of-title memorandum currently under preparation (Matter No. 1017-00003) addresses the registration and ownership structure for each of the 217 titles in detail. For purposes of this jurisdictional analysis, I assume that Aurelius will be the primary named plaintiff, with AMA potentially joined as a co-plaintiff to the extent necessary for titles where AMA holds the relevant registrations or exclusive licenses.

B. Defendant — StreamNow Holdings, Inc.

StreamNow Holdings, Inc. is a Delaware corporation, Delaware Division of Corporations File Number 7291843. StreamNow's corporate headquarters are located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, which falls squarely within the Central District of California, Los Angeles Division. StreamNow's registered agent in Delaware is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.

StreamNow is majority-owned, with an approximate 62% fully diluted ownership stake held by Pinnacle Ventures Fund III, LP, a venture capital fund with offices at 101 California Street, Suite 3500, San Francisco, California 94111. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million. The company operates a streaming "super-aggregator" platform that aggregates content from multiple sources and distributes it to consumers through a combination of subscription, ad-supported, and free ad-supported streaming television ("FAST") channels. StreamNow's platform is available in 14 countries across North America, Europe, and the Asia-Pacific region.

StreamNow's Chief Executive Officer is Derek Calloway, and its Chief Operating Officer is Priya Menon, both of whom are based at StreamNow's Los Angeles headquarters. StreamNow's General Counsel is Tobias Rennert, also based in Los Angeles. Sandra Yee, Vice President of Content Acquisition, is likewise based in Los Angeles and is responsible for overseeing content licensing arrangements, including the arrangement with MDD that is central to this dispute.

StreamNow has retained Grantham Roth & Pearce LLP as outside counsel for this matter. That firm is located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071. The lead partner on the engagement is Victoria Langford, and the associate assigned is Brian Matsuda. The retention of Los Angeles-based outside counsel further confirms StreamNow's deep connections to the Central District of California.

C. Defendant — Meridian Digital Distributors, LLC

Meridian Digital Distributors, LLC is a California limited liability company, California Secretary of State File Number 202115729430. Its registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California, Los Angeles Division.

MDD's sole member and manager is Franklin Ogilvie. The entity was incorporated in late 2021, approximately five months after Ogilvie's departure from Aurelius Media Americas, Inc. The purported Content Distribution Agreement between MDD and StreamNow was allegedly executed on March 15, 2024. Pursuant to that agreement, MDD represented to StreamNow that it possessed the authority to sublicense a portfolio of audiovisual content that, upon inspection, consists almost entirely of Aurelius-owned titles.

Critically, MDD was never authorized by Aurelius or AMA to distribute any Aurelius content. MDD does not appear in Aurelius's authorized distributor records, and no licensing agreement between Aurelius (or AMA) and MDD has been identified. The purported authority under which MDD entered into the Content Distribution Agreement with StreamNow appears to have been fabricated by Ogilvie, who exploited his familiarity with Aurelius's internal systems, title metadata, and licensing documentation from his prior employment at AMA.

D. Defendant — Franklin Ogilvie (Individual)

Franklin Ogilvie is an individual who resides in or around Beverly Hills, California. The address associated with MDD's registration — 8912 Burton Way, Suite 200, Beverly Hills, California 90211 — appears to also serve as Ogilvie's professional address.

Ogilvie was formerly employed as a mid-level licensing manager at Aurelius Media Americas, Inc. from approximately 2017 through June 30, 2021. His employment ended pursuant to a separation agreement dated June 30, 2021. That separation agreement contained, among other provisions, a non-compete clause, a non-solicitation clause, and an express prohibition on the use or exploitation of Aurelius intellectual property, confidential information, and trade secrets following the termination of employment.

All of Ogilvie's relevant conduct in this matter — the formation of MDD, the negotiation and execution of the purported Content Distribution Agreement with StreamNow, and the ongoing unauthorized licensing activities that generated revenue for MDD — occurred in California. Ogilvie's connections to the Central District of California are extensive, longstanding, and directly related to the claims at issue.

E. Nature of the Claims

Aurelius intends to assert the following claims against the Defendants:

1. Federal Copyright Infringement (Direct): Violations of 17 U.S.C. §§ 106 and 501 against StreamNow for the unauthorized reproduction, distribution, and public performance of 217 audiovisual works owned by Aurelius, comprising 142 feature films and 75 television series (1,038 episodes).

2. Contributory Copyright Infringement: Against MDD and Ogilvie for knowingly inducing, causing, and materially contributing to StreamNow's direct infringement by furnishing StreamNow with unauthorized copies and purported licenses for the 217 works.

3. Inducement of Infringement: Against MDD and Ogilvie for actively inducing StreamNow's infringement through the creation and dissemination of the fraudulent Content Distribution Agreement and related licensing documentation.

4. Unfair Business Practices: A claim under California Business and Professions Code § 17200 against all Defendants for engaging in unlawful, unfair, and fraudulent business practices in connection with the unauthorized exploitation of Aurelius's copyrighted works.

5. Tortious Interference with Prospective Economic Advantage: A state-law claim against MDD and Ogilvie for interfering with Aurelius's prospective licensing relationships and revenue streams by flooding the market with unauthorized copies of Aurelius content at below-market rates.

The period of infringement spans approximately April 1, 2024, through January 31, 2026 — a period of approximately 22 months. During this time, StreamNow generated estimated total attributable revenue of $38.6 million from the unauthorized exploitation of Aurelius's content. Preliminary net recoverable damages, as estimated by the Hargrove Economic Consulting Group, total approximately $41.3 million, inclusive of actual damages, disgorgement of profits, and other recoverable amounts. For the 189 titles with timely U.S. copyright registrations, statutory damages and attorneys' fees may also be available under 17 U.S.C. §§ 504(c) and 505.

III. SUBJECT MATTER JURISDICTION

A. Federal Question Jurisdiction — 28 U.S.C. § 1338(a)

The primary basis for subject matter jurisdiction in this action is 28 U.S.C. § 1338(a), which provides:

"The district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents, plant range protection, copyrights and trademarks. No State court shall have jurisdiction over any claim for relief arising under any Act of Congress relating to patents, plant range protection, or copyrights."

Section 1338(a) thus grants the federal district courts both original and exclusive jurisdiction over civil actions arising under the Copyright Act. Aurelius's primary claims in this action arise directly under the United States Copyright Act, specifically 17 U.S.C. §§ 106 and 501. Section 106 sets forth the exclusive rights of copyright owners, including the rights of reproduction, distribution, and public performance. Section 501 defines copyright infringement and provides the basis for civil actions to enforce those exclusive rights.

Aurelius's claims for direct copyright infringement (against StreamNow), contributory copyright infringement (against MDD and Ogilvie), and inducement of infringement (against MDD and Ogilvie) all arise under federal copyright law. It is well established that claims for contributory infringement and inducement are creatures of federal copyright law, deriving from the same statutory framework as direct infringement. See Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005) (recognizing inducement liability under the Copyright Act); Fonovisa, Inc. v. Cherry Auction, Inc., 76 F.3d 259, 261–64 (9th Cir. 1996) (contributory infringement). There is no question that these claims satisfy § 1338(a), and federal courts possess exclusive jurisdiction over them. No state court could entertain these claims.

A critical prerequisite to filing suit, however, is copyright registration. Under Fourth Estate Public Benefit Corp. v. Wall-Street.com, LLC, 139 S. Ct. 881 (2019), the Supreme Court held that registration — not merely application — of a copyright is a prerequisite to instituting a civil action for infringement under 17 U.S.C. § 411(a). This requirement has been satisfied for all 217 titles at issue. The Lexington IP Services copyright registration search, completed on January 22, 2026, confirmed that all 217 works have been registered with the United States Copyright Office. Of these, 189 titles have timely registrations — meaning the registrations were either made within five years of first publication or within three months of first publication (or prior to infringement) — rendering those titles eligible for statutory damages and attorneys' fees under 17 U.S.C. §§ 504(c) and 505. The remaining 28 titles have registrations that postdate the commencement of infringement, and Aurelius's recovery for those titles will be limited to actual damages and disgorgement of profits under § 504(a) and (b). The registration status of each title is detailed in the Lexington IP Services search report appended to the chain-of-title memorandum.

In sum, subject matter jurisdiction under 28 U.S.C. § 1338(a) is beyond dispute.

B. Supplemental Jurisdiction — 28 U.S.C. § 1367

In addition to the federal copyright claims, Aurelius intends to assert two state-law claims: (1) unfair business practices under California Business and Professions Code § 17200, and (2) tortious interference with prospective economic advantage. These state-law claims do not independently confer federal jurisdiction, but the court may exercise supplemental jurisdiction over them under 28 U.S.C. § 1367.

Section 1367(a) provides:

"[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution."

The Supreme Court articulated the governing standard in United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966), holding that supplemental (then "pendent") jurisdiction exists where the federal and state claims derive from a "common nucleus of operative fact" such that a plaintiff "would ordinarily be expected to try them all in one judicial proceeding." Id. at 725.

The § 17200 unfair competition and tortious interference claims in this case are based on the identical factual nucleus as the federal copyright infringement claims. All of the claims arise from a single course of conduct: Ogilvie's unauthorized creation of MDD, MDD's fraudulent representation of licensing authority, the execution of the purported Content Distribution Agreement with StreamNow, and StreamNow's subsequent unauthorized reproduction, distribution, and public performance of 217 Aurelius-owned audiovisual works over a 22-month period. The state-law claims do not require the court to adjudicate any distinct set of facts; rather, they present alternative legal theories grounded in the same events and transactions that give rise to the copyright claims. The "common nucleus of operative fact" test is plainly satisfied.

Furthermore, none of the discretionary bases for declining supplemental jurisdiction under § 1367(c) are present here. The state-law claims do not raise novel or complex issues of California law — Section 17200 unfair competition claims and tortious interference claims are routinely adjudicated in federal court alongside related federal claims. The state-law claims do not substantially predominate over the federal copyright claims, which are the heart of this action. The federal claims have not been dismissed, and there are no exceptional circumstances that would counsel against exercising supplemental jurisdiction.

I note that the question of whether the § 17200 claim may be partially or wholly preempted by the Copyright Act under 17 U.S.C. § 301 is a separate substantive issue that does not affect the jurisdictional analysis. Even if certain aspects of the § 17200 claim were found to be preempted, that determination would go to the merits of the claim rather than the court's jurisdiction. The preemption analysis is reserved for a separate memorandum (Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum, forthcoming). For jurisdictional purposes, it is sufficient that the § 17200 and tortious interference claims are properly before the court under § 1367.

C. Diversity Jurisdiction — 28 U.S.C. § 1332 (Alternative Basis)

As an alternative jurisdictional basis, diversity jurisdiction under 28 U.S.C. § 1332 may be available, though the analysis is somewhat nuanced depending on the identity of the named plaintiff(s).

Aurelius Global Media Group PLC is a citizen of the United Kingdom for diversity purposes. See 28 U.S.C. § 1332(a)(2) (granting jurisdiction over civil actions between "citizens of a State and citizens or subjects of a foreign state"). AMA is a Delaware corporation with its principal place of business in California, making it a citizen of both Delaware and California for diversity purposes. See 28 U.S.C. § 1332(c)(1).

On the defendant side: StreamNow is a Delaware corporation with its principal place of business in California (citizen of Delaware and California). MDD is a California LLC; for diversity purposes, an LLC takes the citizenship of each of its members, see Carden v. Arkoma Associates, Ltd., 494 U.S. 185, 195–96 (1990), and because Ogilvie — MDD's sole member — is a California domiciliary, MDD is a citizen of California. Ogilvie himself is a citizen of California as an individual domiciliary of that state.

If Aurelius, as a foreign corporation, is the sole plaintiff, complete diversity exists as between Aurelius (United Kingdom) and the three domestic defendants (StreamNow — Delaware/California; MDD — California; Ogilvie — California). This satisfies the alienage diversity provision of 28 U.S.C. § 1332(a)(2).

However, a complication arises if AMA is joined as a co-plaintiff. Because AMA is a citizen of California (its principal place of business) and Delaware (its state of incorporation), and because both MDD (California) and Ogilvie (California) are citizens of California, the addition of AMA would destroy complete diversity. AMA's California citizenship is identical to MDD's and Ogilvie's citizenship, defeating the requirement that no plaintiff share citizenship with any defendant. See Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267 (1806).

This potential obstacle is ultimately moot, however, because § 1338(a) provides the primary and dispositive jurisdictional basis for the copyright claims, and § 1367 covers the supplemental state-law claims. Diversity jurisdiction need not be established as a prerequisite to filing. Nevertheless, I recommend referencing § 1332(a)(2) as an alternative jurisdictional basis in the complaint, contingent on Aurelius being the sole named plaintiff. If AMA must be joined as a co-plaintiff for specific titles, the diversity basis should be omitted or qualified accordingly.

The amount-in-controversy requirement of § 1332 is easily satisfied. The estimated preliminary net recoverable damages of $41.3 million far exceed the $75,000 threshold. Even if damages were substantially lower, the amount in controversy would exceed the jurisdictional minimum by orders of magnitude.

Recommendation: Plead 28 U.S.C. § 1338(a) as the primary basis for subject matter jurisdiction. Reference 28 U.S.C. § 1332(a)(2) as an alternative basis if Aurelius (as a foreign entity) is the sole named plaintiff. If AMA is joined as a co-plaintiff, omit the diversity basis and rely exclusively on § 1338(a) and § 1367.

IV. PERSONAL JURISDICTION

The following analysis addresses whether the Central District of California may exercise personal jurisdiction over each of the three prospective defendants. Under California's long-arm statute, Cal. Code Civ. Proc. § 410.10, California courts may exercise jurisdiction "on any basis not inconsistent with the Constitution of this state or of the United States." This provision is coextensive with the outer limits of federal due process, meaning the jurisdictional inquiry reduces to a single constitutional question: whether the exercise of jurisdiction comports with the Due Process Clause of the Fourteenth Amendment (for state courts) or the Fifth Amendment (for federal courts). See Mavrix Photo, Inc. v. Brand Technologies, Inc., 647 F.3d 1218, 1223 (9th Cir. 2011).

As discussed below, all three defendants are subject to both general and specific personal jurisdiction in California, and specifically within the Central District of California.

A. Personal Jurisdiction Over StreamNow Holdings, Inc.

1. General Jurisdiction

StreamNow Holdings, Inc. is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. This address is located within the Central District of California, Los Angeles Division.

Under the Supreme Court's decision in Daimler AG v. Bauman, 571 U.S. 117 (2014), a corporation is subject to general (all-purpose) jurisdiction in the forums where it is "essentially at home." For a corporation, the paradigm bases for general jurisdiction are the state of incorporation and the state where the corporation has its principal place of business. Id. at 137. These two forums represent the prototypical places where general jurisdiction is appropriate, and only in "exceptional" cases will general jurisdiction extend beyond them.

StreamNow's principal place of business is unambiguously Los Angeles, California. Its corporate headquarters are in Los Angeles; its CEO (Derek Calloway), COO (Priya Menon), General Counsel (Tobias Rennert), and VP of Content Acquisition (Sandra Yee) are all based in Los Angeles; and its platform operations, content acquisition, and monetization functions are managed from that location. StreamNow is therefore "at home" in California under Daimler, and the Central District of California may exercise general jurisdiction over it.

StreamNow is also incorporated in Delaware, which provides an independent basis for general jurisdiction in that state. However, that is irrelevant to the California analysis and does not diminish California's jurisdictional authority over StreamNow.

There are no constitutional due process concerns associated with exercising general jurisdiction over StreamNow in California. The company's connections to the forum are not "random," "fortuitous," or "attenuated" — they are foundational. StreamNow is, in every meaningful sense, "at home" in the Central District of California.

2. Specific Jurisdiction (Alternative Basis)

Even if general jurisdiction were somehow disputed — which it should not be — specific jurisdiction over StreamNow is clearly and independently established.

The Ninth Circuit applies a three-part test for specific jurisdiction, as articulated in Axiom Foods, Inc. v. Acerchem International, Inc., 874 F.3d 1064, 1068 (9th Cir. 2017):

(1) The non-resident defendant must purposefully direct its activities or consummate some transaction with the forum or a resident thereof, or perform some act by which the defendant purposefully avails itself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws;

(2) The claim must be one that arises out of or relates to the defendant's forum-related activities; and

(3) The exercise of jurisdiction must be reasonable (i.e., comport with "fair play and substantial justice").

All three prongs are satisfied here.

Purposeful Direction/Availment. StreamNow purposefully directed its infringing activities from its Los Angeles headquarters. The unauthorized ingestion, hosting, streaming, and sublicensing of Aurelius's 217 titles was managed and executed from StreamNow's operations in the Central District. The Content Distribution Agreement with MDD — the instrument through which StreamNow purported to acquire the right to distribute Aurelius content — was negotiated and executed from StreamNow's Los Angeles offices. Sandra Yee, VP of Content Acquisition, who was directly responsible for the MDD relationship, is based in Los Angeles. The November 3, 2025 email in which Yee asserted MDD's sublicensing authority — a key piece of evidence in this matter — emanated from StreamNow's California operations. StreamNow has purposefully availed itself of the privilege of conducting business in California to an extraordinary degree.

Claims Arise Out of Forum-Related Activities. Aurelius's copyright infringement claims arise directly from StreamNow's unauthorized distribution of Aurelius content through its Los Angeles-based operations. There is a direct and proximate causal relationship between StreamNow's forum-related activities and the injuries alleged. This prong is satisfied without difficulty.

Reasonableness. The exercise of jurisdiction over StreamNow in California is eminently reasonable. StreamNow is headquartered in the forum; its key officers and employees are located here; its outside counsel is located here; and the bulk of the evidence — including StreamNow's platform data, content acquisition records, and internal communications — is maintained in California. No burden exists that would render the exercise of jurisdiction unreasonable. The "fair play and substantial justice" standard is more than met. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 477 (1985).

In sum, specific jurisdiction over StreamNow in the Central District of California is clearly established as an alternative to general jurisdiction.

B. Personal Jurisdiction Over Meridian Digital Distributors, LLC

1. General Jurisdiction

MDD is a California limited liability company, formed under California law and assigned California Secretary of State File Number 202115729430. Its registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California, Los Angeles Division.

For unincorporated entities such as LLCs, the analysis of where the entity is "at home" for general jurisdiction purposes follows the same Daimler framework applicable to corporations. The "home" of an unincorporated entity is generally its state of formation and its principal place of business. See BNSF Ry. Co. v. Tyrrell, 581 U.S. 402, 413–14 (2017) (reaffirming Daimler's framework). MDD is formed in California, and its sole known address and place of business is in Beverly Hills, California. MDD is therefore "at home" in California and subject to general jurisdiction in the Central District.

There is no indication that MDD maintains offices, operations, or any significant presence outside of California. Its sole member and manager, Franklin Ogilvie, is a California domiciliary. MDD's connections to California are exclusive and total.

2. Specific Jurisdiction (Alternative)

Even if general jurisdiction over MDD were somehow questioned, specific jurisdiction is easily established. All of MDD's relevant conduct — the purported licensing of Aurelius content to StreamNow, the negotiation and execution of the Content Distribution Agreement on March 15, 2024, and the ongoing receipt of sublicensing revenue from StreamNow — occurred in California. MDD purposefully directed its activities toward the California forum, the claims arise directly from those forum-related activities, and the exercise of jurisdiction is reasonable. All three prongs of the Ninth Circuit's specific jurisdiction test are satisfied.

C. Personal Jurisdiction Over Franklin Ogilvie (Individual)

1. General Jurisdiction

Franklin Ogilvie is an individual who is domiciled in the state of California, residing in or around Beverly Hills. Under the Supreme Court's decision in Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011), an individual is subject to general jurisdiction in his or her state of domicile. Ogilvie's California domicile subjects him to general jurisdiction in California courts, including the Central District of California.

An individual's domicile is determined by physical presence in the state combined with an intent to remain. Ogilvie's residence in the Beverly Hills area, his operation of MDD from a Beverly Hills address, and his prior employment in Los Angeles all confirm that California is his state of domicile. There is no indication that Ogilvie maintains a domicile in any other state.

2. Specific Jurisdiction (Alternative)

Ogilvie's relevant conduct provides an ample basis for specific jurisdiction as well. All of the acts giving rise to Aurelius's claims — the formation and management of MDD, the negotiation and execution of the Content Distribution Agreement with StreamNow, the unauthorized exploitation of Aurelius's intellectual property, and the receipt of licensing revenue — occurred in California. Ogilvie's prior employment at Aurelius Media Americas, Inc., located at 1900 Avenue of the Stars, Los Angeles, California, and the separation agreement he executed on June 30, 2021, further tie him to the forum and establish the factual backdrop for the claims at issue. The purposeful direction, arising-from, and reasonableness prongs are all satisfied with respect to Ogilvie.

No due process concerns are implicated by the exercise of jurisdiction over Ogilvie in California. He is a California resident whose allegedly wrongful conduct was conceived, planned, and executed entirely within the state. The exercise of jurisdiction is not merely reasonable — it is compelled by the facts.

D. Summary of Personal Jurisdiction Analysis

All three prospective defendants — StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie — are subject to both general and specific personal jurisdiction in California, and specifically within the Central District of California. The jurisdictional contacts are overwhelming for each defendant, and no credible motion to dismiss for lack of personal jurisdiction could be sustained.

I note parenthetically that StreamNow's retention of Grantham Roth & Pearce LLP, a Los Angeles-based law firm, as outside counsel for this matter strongly suggests that StreamNow does not intend to contest California jurisdiction. Challenging personal jurisdiction in a forum where a defendant is headquartered and maintains its principal operations would be frivolous and potentially sanctionable.

V. VENUE ANALYSIS

A. Copyright-Specific Venue Statute — 28 U.S.C. § 1400(a)

The venue analysis begins with the copyright-specific venue statute, 28 U.S.C. § 1400(a), which provides:

"Civil actions, suits, or proceedings arising under any Act of Congress relating to copyrights or exclusive rights in mask works may be instituted in the district in which the defendant or his agent resides or may be found."

For purposes of § 1400(a), the term "resides" is interpreted in light of the general venue statute's definition of corporate residence. Under 28 U.S.C. § 1391(c)(2), a corporation is deemed to "reside" in any judicial district in which it is subject to the court's personal jurisdiction with respect to the civil action at the time the action is commenced. For an individual, "resides" means the judicial district in which the individual is domiciled. See 28 U.S.C. § 1391(c)(1).

Applying these definitions to each defendant:

StreamNow Holdings, Inc.: StreamNow is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. As established above, StreamNow is subject to personal jurisdiction in the Central District of California. StreamNow therefore "resides" in this district for purposes of § 1400(a). Venue is proper as to StreamNow.

Meridian Digital Distributors, LLC: MDD's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California. MDD is subject to personal jurisdiction in this district, and therefore "resides" here. Venue is proper as to MDD.

Franklin Ogilvie: Ogilvie is domiciled in the Beverly Hills area, within the Central District of California. He "resides" in this district under § 1391(c)(1). Venue is proper as to Ogilvie.

Because all three defendants reside in the Central District of California, venue is proper in this district under § 1400(a) as to all defendants.

B. General Venue Statute — 28 U.S.C. § 1391(b) (Alternative Basis)

The general venue statute, 28 U.S.C. § 1391(b), provides two independently sufficient alternative bases for venue in the Central District of California.

Section 1391(b)(1): Venue is proper in "a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located." All three defendants reside in California: StreamNow is headquartered in Los Angeles; MDD is registered in Beverly Hills; and Ogilvie is domiciled in Beverly Hills. Moreover, all three defendants reside specifically within the Central District of California. This provision is therefore satisfied, and venue is proper under § 1391(b)(1).

Section 1391(b)(2): Venue is proper in "a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated." The events giving rise to Aurelius's claims occurred overwhelmingly within the Central District of California. The infringing conduct — the ingestion, hosting, and streaming of Aurelius's copyrighted works — was directed from StreamNow's Los Angeles headquarters. The Content Distribution Agreement between MDD and StreamNow was executed in California. Ogilvie formed and operated MDD from Beverly Hills. The unauthorized exploitation of Aurelius's intellectual property was conceived, planned, and executed within this district. A substantial part of the events and omissions giving rise to the claim occurred here, and venue is independently proper under § 1391(b)(2).

Either subsection standing alone would support venue in the Central District of California. Together, they provide an unassailable alternative basis for venue in this forum.

C. Los Angeles Division Specifically

The Central District of California is divided into multiple divisions. StreamNow's headquarters at 3400 Wilshire Boulevard, Los Angeles, California 90010, and MDD's address at 8912 Burton Way, Beverly Hills, California 90211, are both located within the Los Angeles Division of the Central District.

Local Rule 2-1 of the Central District of California governs divisional assignment. Under that rule, cases are assigned to the division in which the events giving rise to the claims principally occurred. Because the principal events in this case — StreamNow's infringing activities, MDD's fraudulent licensing operations, and Ogilvie's unauthorized conduct — all occurred within the geographic boundaries of the Los Angeles Division, assignment to that division is appropriate and expected.

There is no question that the Los Angeles Division is the proper division within the Central District for this action.

D. Considerations Regarding FAST Channel Sublicensees

Our investigation has identified four FAST channel sublicensees that received Aurelius content through StreamNow's platform:

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

These entities are not proposed as defendants in the initial complaint. However, I note for completeness that if any of these entities are later joined as defendants, venue in the Central District of California would remain proper under 28 U.S.C. § 1391(b)(2), as a substantial part of the events giving rise to the claims occurred in this district regardless of where the sublicensees are located. The sublicensees' receipt and further distribution of the infringing content, while relevant to the scope of infringement and damages, does not alter the fact that the originating infringing conduct — the unauthorized licensing and distribution — emanated from the Central District.

The two foreign sublicensees — Velvet Stream Partners, LP (Canada) and Pacific Lantern Digital Pty Ltd (Australia) — raise additional considerations regarding international service of process, the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents, and cross-border enforcement of judgments. Those issues are beyond the scope of this jurisdictional and venue memorandum and would need to be addressed in a separate analysis if joinder of these entities is contemplated.

Recommendation: Focus the initial complaint on StreamNow, MDD, and Ogilvie as the primary defendants. Address the FAST channel sublicensees through separate takedown demands under 17 U.S.C. § 512 and direct cease-and-desist communications. Assess joinder of the domestic sublicensees (Brindoval and BrightLoop) at a later stage based on their compliance with takedown demands and the extent of their independent infringement. Defer joinder of the foreign sublicensees unless their continued infringement warrants the additional complexity and expense of international litigation.

VI. POTENTIAL JURISDICTIONAL CHALLENGES AND COUNTERARGUMENTS

While I do not anticipate any viable jurisdictional challenge from any defendant, I address below the most likely arguments that Defendants' counsel might raise and explain why each would fail.

A. StreamNow's Potential Forum Non Conveniens Argument

StreamNow might argue that the Central District of California is an inconvenient forum and that the case should be dismissed on forum non conveniens grounds. This argument is extremely unlikely to succeed, for several reasons.

First, forum non conveniens is an extraordinary remedy that requires the movant to demonstrate that an adequate alternative forum exists and that the balance of private and public interest factors strongly favors dismissal. See Piper Aircraft Co. v. Reyno, 454 U.S. 235, 255–61 (1981); Dole Food Co. v. Watts, 303 F.3d 1104, 1118 (9th Cir. 2002). Here, no adequate alternative forum has been identified. The United Kingdom — Aurelius's home jurisdiction — is not an appropriate forum for U.S. copyright infringement claims, which arise exclusively under federal law. StreamNow's state of incorporation (Delaware) has no meaningful connection to the underlying facts and would not be a more convenient forum for any party.

Second, the Central District of California is the most convenient forum for all parties, witnesses, and evidence. StreamNow is headquartered here. Its principal officers — Derek Calloway (CEO), Priya Menon (COO), Sandra Yee (VP Content Acquisition), and Tobias Rennert (General Counsel) — are all based in Los Angeles. Its outside counsel, Grantham Roth & Pearce LLP, is in Los Angeles. MDD and Ogilvie are in Beverly Hills. Aurelius's U.S. subsidiary, AMA, is in Los Angeles. The documentary and electronic evidence is concentrated in Los Angeles. No party or witness would be inconvenienced by litigating in this forum.

Third, the Ninth Circuit has consistently held that a defendant who is "at home" in the forum state carries a particularly heavy burden in seeking dismissal on forum non conveniens grounds. StreamNow, as a company headquartered in the Central District, cannot credibly argue that this forum is inconvenient.

A forum non conveniens motion by StreamNow would be meritless and would likely be denied summarily.

B. StreamNow's Potential Motion to Transfer Under 28 U.S.C. § 1404(a)

StreamNow might alternatively seek a transfer of venue under 28 U.S.C. § 1404(a), which permits transfer "[f]or the convenience of parties and witnesses, in the interest of justice" to any other district where the case "might have been brought." This motion would also fail.

The private interest factors under § 1404(a) — including the convenience of the parties, the convenience of witnesses, the relative ease of access to evidence, and the availability of compulsory process — overwhelmingly favor the Central District. All key parties are in the Los Angeles area. The critical witnesses (StreamNow executives, Ogilvie, AMA personnel) are in Los Angeles. The documentary evidence is maintained in Los Angeles. No plausible transferee district offers superior convenience.

The public interest factors — including court congestion, the local interest in resolving local controversies, and the familiarity of the forum with the applicable law — likewise favor the Central District. This dispute involves Los Angeles-based companies and individuals engaging in allegedly infringing conduct directed from Los Angeles. The Central District has a strong local interest in adjudicating this controversy.

Delaware — StreamNow's state of incorporation — is the only other district where venue might technically be proper (based on StreamNow's corporate domicile), but it has no meaningful connection to the facts and would be less convenient for every party, including StreamNow itself. A motion to transfer to Delaware would be contrary to StreamNow's own interests and those of all other parties.

No plausible basis for transfer exists.

C. Challenges to Personal Jurisdiction

As analyzed in detail in Section IV above, all three defendants are subject to general jurisdiction in California. StreamNow is headquartered in Los Angeles; MDD is a California LLC based in Beverly Hills; and Ogilvie is a California domiciliary. No viable challenge to personal jurisdiction exists.

StreamNow, in particular, cannot credibly argue that it lacks minimum contacts with California. The company's headquarters, principal officers, operational staff, and outside counsel are all located in California. Its content acquisition activities — including the Content Distribution Agreement with MDD — were directed from California. StreamNow's connections to the forum are not merely sufficient; they are paradigmatic of the contacts that give rise to general jurisdiction under Daimler.

MDD and Ogilvie face an equally futile jurisdictional challenge. MDD is a California LLC with its only known address in Beverly Hills, and Ogilvie is a California domiciliary who conducted all relevant activities within the state. Any motion to dismiss for lack of personal jurisdiction by either of these defendants would be frivolous.

I do not anticipate that any defendant will raise a personal jurisdiction challenge, but if such a challenge is raised, it will be readily defeated.

D. Standing Considerations

While not strictly a jurisdictional issue in the Article III sense, standing to bring copyright infringement claims requires that the plaintiff be the legal or beneficial owner of an exclusive right under the copyright. See 17 U.S.C. § 501(b).

Aurelius Global Media Group PLC, as the registered copyright owner of the 217 works at issue, has standing to bring copyright infringement claims. The Lexington IP Services search completed January 22, 2026, confirmed that all 217 works are registered with the United States Copyright Office in the name of Aurelius or its predecessor entities, with proper assignments recorded.

Aurelius Media Americas, Inc. may also have standing as a co-owner or exclusive licensee with respect to certain titles, depending on the specific registration and chain of title for each work. The chain-of-title memorandum (Matter No. 1017-00003, forthcoming) will address this issue in detail on a title-by-title basis.

Recommendation: Name Aurelius Global Media Group PLC as the primary plaintiff. If the chain-of-title analysis reveals that AMA holds the relevant registration or exclusive license for specific titles, join AMA as a co-plaintiff for those titles. As discussed in Section III.C above, the addition of AMA as a co-plaintiff may affect the availability of diversity jurisdiction as an alternative basis, but this is immaterial given the strength of the § 1338(a) jurisdictional basis.

VII. RECOMMENDATIONS

Based on the foregoing analysis, I recommend the following:

A. Forum Selection

Aurelius should file its copyright infringement action in the United States District Court for the Central District of California, Los Angeles Division. This forum provides the strongest jurisdictional basis, the most convenient venue for all parties, and the greatest strategic advantages for Aurelius. No other forum offers a comparable combination of jurisdictional certainty, geographic convenience, and procedural efficiency. The Central District of California's familiarity with complex intellectual property disputes, its well-developed local rules for such cases, and the concentration of relevant parties, witnesses, and evidence in the Los Angeles area make it the optimal forum for this action.

B. Jurisdictional Allegations in Complaint

The complaint should contain the following jurisdictional and venue allegations:

1. Federal Subject Matter Jurisdiction: Plead 28 U.S.C. § 1338(a) as the primary basis for subject matter jurisdiction, identifying the claims as arising under the United States Copyright Act, 17 U.S.C. §§ 106 and 501.

2. Supplemental Jurisdiction: Plead 28 U.S.C. § 1367 as the basis for jurisdiction over the California Business and Professions Code § 17200 unfair competition claim and the tortious interference with prospective economic advantage claim, alleging that these state-law claims arise from the same case or controversy as the federal copyright claims.

3. Diversity Jurisdiction (Alternative): If Aurelius is the sole named plaintiff, reference 28 U.S.C. § 1332(a)(2) as an alternative jurisdictional basis, alleging that the action is between a citizen of a foreign state (Aurelius, United Kingdom) and citizens of a State (StreamNow — Delaware/California; MDD — California; Ogilvie — California), and that the amount in controversy exceeds $75,000 exclusive of interest and costs.

4. Venue: Allege venue under 28 U.S.C. § 1400(a) as the primary basis, and alternatively under 28 U.S.C. § 1391(b)(1) (all defendants reside in California and in the Central District) and § 1391(b)(2) (substantial part of the events occurred in the Central District).

5. Personal Jurisdiction: Allege personal jurisdiction over each defendant separately, citing both general jurisdiction (domicile, headquarters, or principal place of business in California) and specific jurisdiction (forum-related infringing conduct, purposeful direction of activities toward the forum, and the reasonableness of exercising jurisdiction).

C. Service of Process

Service of process should be effectuated as follows:

StreamNow Holdings, Inc.: Serve via StreamNow's registered agent, Capitol Registered Agents, Inc., 1209 Orange Street, Wilmington, Delaware 19801, pursuant to Federal Rule of Civil Procedure 4(h)(1)(B), which permits service on a corporation by delivering a copy of the summons and complaint to an officer, a managing or general agent, or any agent authorized by appointment or by law to receive service of process. Alternatively, StreamNow may be served through its General Counsel, Tobias Rennert, at StreamNow's headquarters, 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, pursuant to Federal Rule of Civil Procedure 4(h)(1)(A), which incorporates state law methods of service, including California Code of Civil Procedure § 416.10 (service on a corporation by delivering to a person designated as agent for service or to the president, other head of the corporation, vice president, secretary, assistant secretary, treasurer, assistant treasurer, controller, or general manager).

Meridian Digital Distributors, LLC: Serve Franklin Ogilvie, as MDD's sole member and manager, at 8912 Burton Way, Suite 200, Beverly Hills, California 90211, pursuant to Federal Rule of Civil Procedure 4(h)(1)(A), incorporating California Code of Civil Procedure § 416.40 (service on an unincorporated association by delivering to the person designated as agent for service of process or, if none, to the president or other head of the association, a vice president, a secretary or assistant secretary, a treasurer or assistant treasurer, a general manager, or a person authorized to receive service on behalf of the association).

Franklin Ogilvie (Individually): Serve by personal service at Ogilvie's known address in the Beverly Hills area, pursuant to Federal Rule of Civil Procedure 4(e), which permits service by following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located (California) or in the state where service is made. Under California Code of Civil Procedure § 415.10, an individual may be served by personal delivery of a copy of the summons and complaint to the person to be served. If personal service cannot be accomplished after reasonable diligence, substituted service under California Code of Civil Procedure § 415.20(b) is available.

I recommend serving all three defendants simultaneously to minimize the risk of informal coordination among defendants in advance of the responsive pleading deadline.

VIII. CONCLUSION

The United States District Court for the Central District of California, Los Angeles Division, is the proper and optimal forum for Aurelius Global Media Group PLC's copyright infringement action against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie.

Subject matter jurisdiction is firmly established under 28 U.S.C. § 1338(a), which grants federal courts original and exclusive jurisdiction over claims arising under the Copyright Act. Supplemental jurisdiction under 28 U.S.C. § 1367 extends the court's jurisdiction to the state-law claims for unfair business practices under California Business and Professions Code § 17200 and tortious interference with prospective economic advantage, both of which arise from the same common nucleus of operative fact as the federal copyright claims. Diversity jurisdiction under 28 U.S.C. § 1332(a)(2) provides an additional alternative basis if Aurelius is the sole named plaintiff.

Personal jurisdiction exists over all three defendants on both general and specific jurisdiction grounds. StreamNow is headquartered in Los Angeles and is "at home" in California under Daimler. MDD is a California LLC with its sole address in Beverly Hills. Ogilvie is a California domiciliary who conducted all relevant activities within the state. No defendant can credibly contest personal jurisdiction in this forum.

Venue is proper under the copyright-specific venue statute, 28 U.S.C. § 1400(a), as all defendants reside in the Central District. Venue is independently proper under the general venue statute, 28 U.S.C. § 1391(b)(1) and (b)(2), as all defendants reside in California and a substantial part of the events giving rise to the claims occurred within the Central District.

No viable jurisdictional or venue challenge is anticipated from any defendant. Any motion to dismiss for lack of jurisdiction, motion to transfer, or motion to dismiss on forum non conveniens grounds would lack merit and would be denied.

I recommend proceeding with the preparation of the draft complaint for filing in this forum. I am available to discuss any aspect of this analysis and to assist with the drafting of the jurisdictional and venue allegations for the complaint.

•

APPENDIX — REFERENCED MATERIALS

The following documents are referenced in this memorandum and are either attached, forthcoming, or available upon request:

1. Draft Complaint — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al. (forthcoming; to be prepared upon approval of forum selection).

2. Chain-of-Title Memorandum — Matter No. 1017-00003 (forthcoming; will address copyright ownership, registration chain, and standing for each of the 217 titles at issue).

3. Copyright Registration Summary Report — Prepared by Lexington IP Services; search completed January 22, 2026 (confirms registration status of all 217 titles, including registration numbers, effective dates, and timeliness determinations for statutory damages eligibility).

4. CipherTrace Forensic Analysis Summary — (forthcoming; will address digital forensic findings regarding StreamNow's ingestion and distribution of Aurelius content, metadata analysis, and attribution of unauthorized access to MDD/Ogilvie).

5. Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum — (forthcoming; will address Copyright Act preemption analysis and viability of the § 17200 claim).

Prepared by Omar Siddiqui, Associate. Please direct any questions or comments to the undersigned at osiddiqui@[firm].com or extension 4217.

MEMORANDUM
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT
TO: Marcus Delgado, Partner; Wendy Schultz, Senior Associate
FROM: Omar Siddiqui, Associate
DATE: February 27, 2026
RE: Jurisdictional & Venue Analysis — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al.
MATTER NO.: 1017-00003
CLIENT: Aurelius Global Media Group PLC
This memorandum is protected by the attorney-client privilege, the work product doctrine, and all other applicable privileges. It is intended solely for the use of the individuals identified above and other members of the engagement team. Do not distribute, copy, or disclose this memorandum or its contents without the express written authorization of the undersigned or a partner on this matter. Any inadvertent disclosure does not constitute a waiver of any applicable privilege.
I. EXECUTIVE SUMMARY
You have asked me to analyze whether the United States District Court for the Central District of California, Los Angeles Division, is the proper forum for Aurelius Global Media Group PLC's ("Aurelius") anticipated copyright infringement action against StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie (collectively, "Defendants"). This memorandum examines federal subject matter jurisdiction, personal jurisdiction over each prospective defendant, and venue, and addresses potential jurisdictional challenges the Defendants may raise.
Conclusion. Based on the analysis set forth below, the Central District of California, Los Angeles Division, is the appropriate forum for this action, and I recommend filing in that court. Federal subject matter jurisdiction is firmly established under 28 U.S.C. § 1338(a), which grants federal district courts original and exclusive jurisdiction over civil actions arising under the Copyright Act, 17 U.S.C. §§ 106, 501. Supplemental jurisdiction under 28 U.S.C. § 1367 covers the state-law unfair competition claim brought under California Business and Professions Code § 17200 and the tortious interference with prospective economic advantage claim, as both arise from the same common nucleus of operative fact as the federal copyright claims. Diversity jurisdiction under 28 U.S.C. § 1332(a)(2) provides an alternative basis if Aurelius, as a foreign entity, is the sole named plaintiff. Personal jurisdiction — both general and specific — exists over all three prospective defendants: StreamNow is headquartered in Los Angeles; MDD is a California LLC with its registered address in Beverly Hills; and Ogilvie is a California domiciliary who resides in the Beverly Hills area. Venue is proper under the copyright-specific venue statute, 28 U.S.C. § 1400(a), and alternatively under the general venue statute, 28 U.S.C. § 1391(b)(1) and (b)(2). No viable jurisdictional or venue challenge is anticipated from any defendant.
II. FACTUAL BACKGROUND RELEVANT TO JURISDICTION AND VENUE
The following factual summary is drawn from client documents, internal investigation materials, the Lexington IP Services copyright registration search completed January 22, 2026, and the preliminary findings of the CipherTrace forensic analysis. This summary is limited to facts bearing on jurisdiction and venue; a comprehensive factual recitation will be included in the forthcoming draft complaint and the accompanying statement of facts memorandum.
A. The Plaintiff — Aurelius Global Media Group PLC
Aurelius Global Media Group PLC is a United Kingdom public limited company registered with Companies House under Registration Number 08724561. Its corporate headquarters are located at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Exchange under the Alternative Investment Market (AIM: AGLM), and its American Depositary Receipts ("ADRs") are traded over-the-counter in the United States.
Aurelius conducts its U.S. operations through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), which maintains its principal offices at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA is responsible for content licensing, distribution, and production activities within North America and serves as Aurelius's primary point of contact with U.S.-based platform partners, distributors, and talent agencies.
For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). The company's content library consists of more than 4,200 titles spanning film, television, and digital media. Of these, 217 titles are at issue in this matter: 142 feature films and 75 television series comprising a total of 1,038 individual episodes. These works represent a significant and commercially valuable portion of Aurelius's catalog.
As a threshold matter, I note that Aurelius may file this action as plaintiff directly, or alternatively through AMA. Both entities possess standing as copyright holders with respect to the works at issue. The chain-of-title memorandum currently under preparation (Matter No. 1017-00003) addresses the registration and ownership structure for each of the 217 titles in detail. For purposes of this jurisdictional analysis, I assume that Aurelius will be the primary named plaintiff, with AMA potentially joined as a co-plaintiff to the extent necessary for titles where AMA holds the relevant registrations or exclusive licenses.
B. Defendant — StreamNow Holdings, Inc.
StreamNow Holdings, Inc. is a Delaware corporation, Delaware Division of Corporations File Number 7291843. StreamNow's corporate headquarters are located at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, which falls squarely within the Central District of California, Los Angeles Division. StreamNow's registered agent in Delaware is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.
StreamNow is majority-owned, with an approximate 62% fully diluted ownership stake held by Pinnacle Ventures Fund III, LP, a venture capital fund with offices at 101 California Street, Suite 3500, San Francisco, California 94111. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million. The company operates a streaming "super-aggregator" platform that aggregates content from multiple sources and distributes it to consumers through a combination of subscription, ad-supported, and free ad-supported streaming television ("FAST") channels. StreamNow's platform is available in 14 countries across North America, Europe, and the Asia-Pacific region.
StreamNow's Chief Executive Officer is Derek Calloway, and its Chief Operating Officer is Priya Menon, both of whom are based at StreamNow's Los Angeles headquarters. StreamNow's General Counsel is Tobias Rennert, also based in Los Angeles. Sandra Yee, Vice President of Content Acquisition, is likewise based in Los Angeles and is responsible for overseeing content licensing arrangements, including the arrangement with MDD that is central to this dispute.
StreamNow has retained Grantham Roth & Pearce LLP as outside counsel for this matter. That firm is located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071. The lead partner on the engagement is Victoria Langford, and the associate assigned is Brian Matsuda. The retention of Los Angeles-based outside counsel further confirms StreamNow's deep connections to the Central District of California.
C. Defendant — Meridian Digital Distributors, LLC
Meridian Digital Distributors, LLC is a California limited liability company, California Secretary of State File Number 202115729430. Its registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California, Los Angeles Division.
MDD's sole member and manager is Franklin Ogilvie. The entity was incorporated in late 2021, approximately five months after Ogilvie's departure from Aurelius Media Americas, Inc. The purported Content Distribution Agreement between MDD and StreamNow was allegedly executed on March 15, 2024. Pursuant to that agreement, MDD represented to StreamNow that it possessed the authority to sublicense a portfolio of audiovisual content that, upon inspection, consists almost entirely of Aurelius-owned titles.
Critically, MDD was never authorized by Aurelius or AMA to distribute any Aurelius content. MDD does not appear in Aurelius's authorized distributor records, and no licensing agreement between Aurelius (or AMA) and MDD has been identified. The purported authority under which MDD entered into the Content Distribution Agreement with StreamNow appears to have been fabricated by Ogilvie, who exploited his familiarity with Aurelius's internal systems, title metadata, and licensing documentation from his prior employment at AMA.
D. Defendant — Franklin Ogilvie (Individual)
Franklin Ogilvie is an individual who resides in or around Beverly Hills, California. The address associated with MDD's registration — 8912 Burton Way, Suite 200, Beverly Hills, California 90211 — appears to also serve as Ogilvie's professional address.
Ogilvie was formerly employed as a mid-level licensing manager at Aurelius Media Americas, Inc. from approximately 2017 through June 30, 2021. His employment ended pursuant to a separation agreement dated June 30, 2021. That separation agreement contained, among other provisions, a non-compete clause, a non-solicitation clause, and an express prohibition on the use or exploitation of Aurelius intellectual property, confidential information, and trade secrets following the termination of employment.
All of Ogilvie's relevant conduct in this matter — the formation of MDD, the negotiation and execution of the purported Content Distribution Agreement with StreamNow, and the ongoing unauthorized licensing activities that generated revenue for MDD — occurred in California. Ogilvie's connections to the Central District of California are extensive, longstanding, and directly related to the claims at issue.
E. Nature of the Claims
Aurelius intends to assert the following claims against the Defendants:
1. Federal Copyright Infringement (Direct): Violations of 17 U.S.C. §§ 106 and 501 against StreamNow for the unauthorized reproduction, distribution, and public performance of 217 audiovisual works owned by Aurelius, comprising 142 feature films and 75 television series (1,038 episodes).
2. Contributory Copyright Infringement: Against MDD and Ogilvie for knowingly inducing, causing, and materially contributing to StreamNow's direct infringement by furnishing StreamNow with unauthorized copies and purported licenses for the 217 works.
3. Inducement of Infringement: Against MDD and Ogilvie for actively inducing StreamNow's infringement through the creation and dissemination of the fraudulent Content Distribution Agreement and related licensing documentation.
4. Unfair Business Practices: A claim under California Business and Professions Code § 17200 against all Defendants for engaging in unlawful, unfair, and fraudulent business practices in connection with the unauthorized exploitation of Aurelius's copyrighted works.
5. Tortious Interference with Prospective Economic Advantage: A state-law claim against MDD and Ogilvie for interfering with Aurelius's prospective licensing relationships and revenue streams by flooding the market with unauthorized copies of Aurelius content at below-market rates.
The period of infringement spans approximately April 1, 2024, through January 31, 2026 — a period of approximately 22 months. During this time, StreamNow generated estimated total attributable revenue of $38.6 million from the unauthorized exploitation of Aurelius's content. Preliminary net recoverable damages, as estimated by the Hargrove Economic Consulting Group, total approximately $41.3 million, inclusive of actual damages, disgorgement of profits, and other recoverable amounts. For the 189 titles with timely U.S. copyright registrations, statutory damages and attorneys' fees may also be available under 17 U.S.C. §§ 504(c) and 505.
III. SUBJECT MATTER JURISDICTION
A. Federal Question Jurisdiction — 28 U.S.C. § 1338(a)
The primary basis for subject matter jurisdiction in this action is 28 U.S.C. § 1338(a), which provides:
"The district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents, plant range protection, copyrights and trademarks. No State court shall have jurisdiction over any claim for relief arising under any Act of Congress relating to patents, plant range protection, or copyrights."
Section 1338(a) thus grants the federal district courts both original and exclusive jurisdiction over civil actions arising under the Copyright Act. Aurelius's primary claims in this action arise directly under the United States Copyright Act, specifically 17 U.S.C. §§ 106 and 501. Section 106 sets forth the exclusive rights of copyright owners, including the rights of reproduction, distribution, and public performance. Section 501 defines copyright infringement and provides the basis for civil actions to enforce those exclusive rights.
Aurelius's claims for direct copyright infringement (against StreamNow), contributory copyright infringement (against MDD and Ogilvie), and inducement of infringement (against MDD and Ogilvie) all arise under federal copyright law. It is well established that claims for contributory infringement and inducement are creatures of federal copyright law, deriving from the same statutory framework as direct infringement. See Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005) (recognizing inducement liability under the Copyright Act); Fonovisa, Inc. v. Cherry Auction, Inc., 76 F.3d 259, 261–64 (9th Cir. 1996) (contributory infringement). There is no question that these claims satisfy § 1338(a), and federal courts possess exclusive jurisdiction over them. No state court could entertain these claims.
A critical prerequisite to filing suit, however, is copyright registration. Under Fourth Estate Public Benefit Corp. v. Wall-Street.com, LLC, 139 S. Ct. 881 (2019), the Supreme Court held that registration — not merely application — of a copyright is a prerequisite to instituting a civil action for infringement under 17 U.S.C. § 411(a). This requirement has been satisfied for all 217 titles at issue. The Lexington IP Services copyright registration search, completed on January 22, 2026, confirmed that all 217 works have been registered with the United States Copyright Office. Of these, 189 titles have timely registrations — meaning the registrations were either made within five years of first publication or within three months of first publication (or prior to infringement) — rendering those titles eligible for statutory damages and attorneys' fees under 17 U.S.C. §§ 504(c) and 505. The remaining 28 titles have registrations that postdate the commencement of infringement, and Aurelius's recovery for those titles will be limited to actual damages and disgorgement of profits under § 504(a) and (b). The registration status of each title is detailed in the Lexington IP Services search report appended to the chain-of-title memorandum.
In sum, subject matter jurisdiction under 28 U.S.C. § 1338(a) is beyond dispute.
B. Supplemental Jurisdiction — 28 U.S.C. § 1367
In addition to the federal copyright claims, Aurelius intends to assert two state-law claims: (1) unfair business practices under California Business and Professions Code § 17200, and (2) tortious interference with prospective economic advantage. These state-law claims do not independently confer federal jurisdiction, but the court may exercise supplemental jurisdiction over them under 28 U.S.C. § 1367.
Section 1367(a) provides:
"[I]n any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution."
The Supreme Court articulated the governing standard in United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966), holding that supplemental (then "pendent") jurisdiction exists where the federal and state claims derive from a "common nucleus of operative fact" such that a plaintiff "would ordinarily be expected to try them all in one judicial proceeding." Id. at 725.
The § 17200 unfair competition and tortious interference claims in this case are based on the identical factual nucleus as the federal copyright infringement claims. All of the claims arise from a single course of conduct: Ogilvie's unauthorized creation of MDD, MDD's fraudulent representation of licensing authority, the execution of the purported Content Distribution Agreement with StreamNow, and StreamNow's subsequent unauthorized reproduction, distribution, and public performance of 217 Aurelius-owned audiovisual works over a 22-month period. The state-law claims do not require the court to adjudicate any distinct set of facts; rather, they present alternative legal theories grounded in the same events and transactions that give rise to the copyright claims. The "common nucleus of operative fact" test is plainly satisfied.
Furthermore, none of the discretionary bases for declining supplemental jurisdiction under § 1367(c) are present here. The state-law claims do not raise novel or complex issues of California law — Section 17200 unfair competition claims and tortious interference claims are routinely adjudicated in federal court alongside related federal claims. The state-law claims do not substantially predominate over the federal copyright claims, which are the heart of this action. The federal claims have not been dismissed, and there are no exceptional circumstances that would counsel against exercising supplemental jurisdiction.
I note that the question of whether the § 17200 claim may be partially or wholly preempted by the Copyright Act under 17 U.S.C. § 301 is a separate substantive issue that does not affect the jurisdictional analysis. Even if certain aspects of the § 17200 claim were found to be preempted, that determination would go to the merits of the claim rather than the court's jurisdiction. The preemption analysis is reserved for a separate memorandum (Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum, forthcoming). For jurisdictional purposes, it is sufficient that the § 17200 and tortious interference claims are properly before the court under § 1367.
C. Diversity Jurisdiction — 28 U.S.C. § 1332 (Alternative Basis)
As an alternative jurisdictional basis, diversity jurisdiction under 28 U.S.C. § 1332 may be available, though the analysis is somewhat nuanced depending on the identity of the named plaintiff(s).
Aurelius Global Media Group PLC is a citizen of the United Kingdom for diversity purposes. See 28 U.S.C. § 1332(a)(2) (granting jurisdiction over civil actions between "citizens of a State and citizens or subjects of a foreign state"). AMA is a Delaware corporation with its principal place of business in California, making it a citizen of both Delaware and California for diversity purposes. See 28 U.S.C. § 1332(c)(1).
On the defendant side: StreamNow is a Delaware corporation with its principal place of business in California (citizen of Delaware and California). MDD is a California LLC; for diversity purposes, an LLC takes the citizenship of each of its members, see Carden v. Arkoma Associates, Ltd., 494 U.S. 185, 195–96 (1990), and because Ogilvie — MDD's sole member — is a California domiciliary, MDD is a citizen of California. Ogilvie himself is a citizen of California as an individual domiciliary of that state.
If Aurelius, as a foreign corporation, is the sole plaintiff, complete diversity exists as between Aurelius (United Kingdom) and the three domestic defendants (StreamNow — Delaware/California; MDD — California; Ogilvie — California). This satisfies the alienage diversity provision of 28 U.S.C. § 1332(a)(2).
However, a complication arises if AMA is joined as a co-plaintiff. Because AMA is a citizen of California (its principal place of business) and Delaware (its state of incorporation), and because both MDD (California) and Ogilvie (California) are citizens of California, the addition of AMA would destroy complete diversity. AMA's California citizenship is identical to MDD's and Ogilvie's citizenship, defeating the requirement that no plaintiff share citizenship with any defendant. See Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267 (1806).
This potential obstacle is ultimately moot, however, because § 1338(a) provides the primary and dispositive jurisdictional basis for the copyright claims, and § 1367 covers the supplemental state-law claims. Diversity jurisdiction need not be established as a prerequisite to filing. Nevertheless, I recommend referencing § 1332(a)(2) as an alternative jurisdictional basis in the complaint, contingent on Aurelius being the sole named plaintiff. If AMA must be joined as a co-plaintiff for specific titles, the diversity basis should be omitted or qualified accordingly.
The amount-in-controversy requirement of § 1332 is easily satisfied. The estimated preliminary net recoverable damages of $41.3 million far exceed the $75,000 threshold. Even if damages were substantially lower, the amount in controversy would exceed the jurisdictional minimum by orders of magnitude.
Recommendation: Plead 28 U.S.C. § 1338(a) as the primary basis for subject matter jurisdiction. Reference 28 U.S.C. § 1332(a)(2) as an alternative basis if Aurelius (as a foreign entity) is the sole named plaintiff. If AMA is joined as a co-plaintiff, omit the diversity basis and rely exclusively on § 1338(a) and § 1367.
IV. PERSONAL JURISDICTION
The following analysis addresses whether the Central District of California may exercise personal jurisdiction over each of the three prospective defendants. Under California's long-arm statute, Cal. Code Civ. Proc. § 410.10, California courts may exercise jurisdiction "on any basis not inconsistent with the Constitution of this state or of the United States." This provision is coextensive with the outer limits of federal due process, meaning the jurisdictional inquiry reduces to a single constitutional question: whether the exercise of jurisdiction comports with the Due Process Clause of the Fourteenth Amendment (for state courts) or the Fifth Amendment (for federal courts). See Mavrix Photo, Inc. v. Brand Technologies, Inc., 647 F.3d 1218, 1223 (9th Cir. 2011).
As discussed below, all three defendants are subject to both general and specific personal jurisdiction in California, and specifically within the Central District of California.
A. Personal Jurisdiction Over StreamNow Holdings, Inc.
1. General Jurisdiction
StreamNow Holdings, Inc. is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. This address is located within the Central District of California, Los Angeles Division.
Under the Supreme Court's decision in Daimler AG v. Bauman, 571 U.S. 117 (2014), a corporation is subject to general (all-purpose) jurisdiction in the forums where it is "essentially at home." For a corporation, the paradigm bases for general jurisdiction are the state of incorporation and the state where the corporation has its principal place of business. Id. at 137. These two forums represent the prototypical places where general jurisdiction is appropriate, and only in "exceptional" cases will general jurisdiction extend beyond them.
StreamNow's principal place of business is unambiguously Los Angeles, California. Its corporate headquarters are in Los Angeles; its CEO (Derek Calloway), COO (Priya Menon), General Counsel (Tobias Rennert), and VP of Content Acquisition (Sandra Yee) are all based in Los Angeles; and its platform operations, content acquisition, and monetization functions are managed from that location. StreamNow is therefore "at home" in California under Daimler, and the Central District of California may exercise general jurisdiction over it.
StreamNow is also incorporated in Delaware, which provides an independent basis for general jurisdiction in that state. However, that is irrelevant to the California analysis and does not diminish California's jurisdictional authority over StreamNow.
There are no constitutional due process concerns associated with exercising general jurisdiction over StreamNow in California. The company's connections to the forum are not "random," "fortuitous," or "attenuated" — they are foundational. StreamNow is, in every meaningful sense, "at home" in the Central District of California.
2. Specific Jurisdiction (Alternative Basis)
Even if general jurisdiction were somehow disputed — which it should not be — specific jurisdiction over StreamNow is clearly and independently established.
The Ninth Circuit applies a three-part test for specific jurisdiction, as articulated in Axiom Foods, Inc. v. Acerchem International, Inc., 874 F.3d 1064, 1068 (9th Cir. 2017):
(1) The non-resident defendant must purposefully direct its activities or consummate some transaction with the forum or a resident thereof, or perform some act by which the defendant purposefully avails itself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws;
(2) The claim must be one that arises out of or relates to the defendant's forum-related activities; and
(3) The exercise of jurisdiction must be reasonable (i.e., comport with "fair play and substantial justice").
All three prongs are satisfied here.
Purposeful Direction/Availment. StreamNow purposefully directed its infringing activities from its Los Angeles headquarters. The unauthorized ingestion, hosting, streaming, and sublicensing of Aurelius's 217 titles was managed and executed from StreamNow's operations in the Central District. The Content Distribution Agreement with MDD — the instrument through which StreamNow purported to acquire the right to distribute Aurelius content — was negotiated and executed from StreamNow's Los Angeles offices. Sandra Yee, VP of Content Acquisition, who was directly responsible for the MDD relationship, is based in Los Angeles. The November 3, 2025 email in which Yee asserted MDD's sublicensing authority — a key piece of evidence in this matter — emanated from StreamNow's California operations. StreamNow has purposefully availed itself of the privilege of conducting business in California to an extraordinary degree.
Claims Arise Out of Forum-Related Activities. Aurelius's copyright infringement claims arise directly from StreamNow's unauthorized distribution of Aurelius content through its Los Angeles-based operations. There is a direct and proximate causal relationship between StreamNow's forum-related activities and the injuries alleged. This prong is satisfied without difficulty.
Reasonableness. The exercise of jurisdiction over StreamNow in California is eminently reasonable. StreamNow is headquartered in the forum; its key officers and employees are located here; its outside counsel is located here; and the bulk of the evidence — including StreamNow's platform data, content acquisition records, and internal communications — is maintained in California. No burden exists that would render the exercise of jurisdiction unreasonable. The "fair play and substantial justice" standard is more than met. See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 477 (1985).
In sum, specific jurisdiction over StreamNow in the Central District of California is clearly established as an alternative to general jurisdiction.
B. Personal Jurisdiction Over Meridian Digital Distributors, LLC
1. General Jurisdiction
MDD is a California limited liability company, formed under California law and assigned California Secretary of State File Number 202115729430. Its registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California, Los Angeles Division.
For unincorporated entities such as LLCs, the analysis of where the entity is "at home" for general jurisdiction purposes follows the same Daimler framework applicable to corporations. The "home" of an unincorporated entity is generally its state of formation and its principal place of business. See BNSF Ry. Co. v. Tyrrell, 581 U.S. 402, 413–14 (2017) (reaffirming Daimler's framework). MDD is formed in California, and its sole known address and place of business is in Beverly Hills, California. MDD is therefore "at home" in California and subject to general jurisdiction in the Central District.
There is no indication that MDD maintains offices, operations, or any significant presence outside of California. Its sole member and manager, Franklin Ogilvie, is a California domiciliary. MDD's connections to California are exclusive and total.
2. Specific Jurisdiction (Alternative)
Even if general jurisdiction over MDD were somehow questioned, specific jurisdiction is easily established. All of MDD's relevant conduct — the purported licensing of Aurelius content to StreamNow, the negotiation and execution of the Content Distribution Agreement on March 15, 2024, and the ongoing receipt of sublicensing revenue from StreamNow — occurred in California. MDD purposefully directed its activities toward the California forum, the claims arise directly from those forum-related activities, and the exercise of jurisdiction is reasonable. All three prongs of the Ninth Circuit's specific jurisdiction test are satisfied.
C. Personal Jurisdiction Over Franklin Ogilvie (Individual)
1. General Jurisdiction
Franklin Ogilvie is an individual who is domiciled in the state of California, residing in or around Beverly Hills. Under the Supreme Court's decision in Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 924 (2011), an individual is subject to general jurisdiction in his or her state of domicile. Ogilvie's California domicile subjects him to general jurisdiction in California courts, including the Central District of California.
An individual's domicile is determined by physical presence in the state combined with an intent to remain. Ogilvie's residence in the Beverly Hills area, his operation of MDD from a Beverly Hills address, and his prior employment in Los Angeles all confirm that California is his state of domicile. There is no indication that Ogilvie maintains a domicile in any other state.
2. Specific Jurisdiction (Alternative)
Ogilvie's relevant conduct provides an ample basis for specific jurisdiction as well. All of the acts giving rise to Aurelius's claims — the formation and management of MDD, the negotiation and execution of the Content Distribution Agreement with StreamNow, the unauthorized exploitation of Aurelius's intellectual property, and the receipt of licensing revenue — occurred in California. Ogilvie's prior employment at Aurelius Media Americas, Inc., located at 1900 Avenue of the Stars, Los Angeles, California, and the separation agreement he executed on June 30, 2021, further tie him to the forum and establish the factual backdrop for the claims at issue. The purposeful direction, arising-from, and reasonableness prongs are all satisfied with respect to Ogilvie.
No due process concerns are implicated by the exercise of jurisdiction over Ogilvie in California. He is a California resident whose allegedly wrongful conduct was conceived, planned, and executed entirely within the state. The exercise of jurisdiction is not merely reasonable — it is compelled by the facts.
D. Summary of Personal Jurisdiction Analysis
All three prospective defendants — StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie — are subject to both general and specific personal jurisdiction in California, and specifically within the Central District of California. The jurisdictional contacts are overwhelming for each defendant, and no credible motion to dismiss for lack of personal jurisdiction could be sustained.
I note parenthetically that StreamNow's retention of Grantham Roth & Pearce LLP, a Los Angeles-based law firm, as outside counsel for this matter strongly suggests that StreamNow does not intend to contest California jurisdiction. Challenging personal jurisdiction in a forum where a defendant is headquartered and maintains its principal operations would be frivolous and potentially sanctionable.
V. VENUE ANALYSIS
A. Copyright-Specific Venue Statute — 28 U.S.C. § 1400(a)
The venue analysis begins with the copyright-specific venue statute, 28 U.S.C. § 1400(a), which provides:
"Civil actions, suits, or proceedings arising under any Act of Congress relating to copyrights or exclusive rights in mask works may be instituted in the district in which the defendant or his agent resides or may be found."
For purposes of § 1400(a), the term "resides" is interpreted in light of the general venue statute's definition of corporate residence. Under 28 U.S.C. § 1391(c)(2), a corporation is deemed to "reside" in any judicial district in which it is subject to the court's personal jurisdiction with respect to the civil action at the time the action is commenced. For an individual, "resides" means the judicial district in which the individual is domiciled. See 28 U.S.C. § 1391(c)(1).
Applying these definitions to each defendant:
StreamNow Holdings, Inc.: StreamNow is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. As established above, StreamNow is subject to personal jurisdiction in the Central District of California. StreamNow therefore "resides" in this district for purposes of § 1400(a). Venue is proper as to StreamNow.
Meridian Digital Distributors, LLC: MDD's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211, which is within the Central District of California. MDD is subject to personal jurisdiction in this district, and therefore "resides" here. Venue is proper as to MDD.
Franklin Ogilvie: Ogilvie is domiciled in the Beverly Hills area, within the Central District of California. He "resides" in this district under § 1391(c)(1). Venue is proper as to Ogilvie.
Because all three defendants reside in the Central District of California, venue is proper in this district under § 1400(a) as to all defendants.
B. General Venue Statute — 28 U.S.C. § 1391(b) (Alternative Basis)
The general venue statute, 28 U.S.C. § 1391(b), provides two independently sufficient alternative bases for venue in the Central District of California.
Section 1391(b)(1): Venue is proper in "a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located." All three defendants reside in California: StreamNow is headquartered in Los Angeles; MDD is registered in Beverly Hills; and Ogilvie is domiciled in Beverly Hills. Moreover, all three defendants reside specifically within the Central District of California. This provision is therefore satisfied, and venue is proper under § 1391(b)(1).
Section 1391(b)(2): Venue is proper in "a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated." The events giving rise to Aurelius's claims occurred overwhelmingly within the Central District of California. The infringing conduct — the ingestion, hosting, and streaming of Aurelius's copyrighted works — was directed from StreamNow's Los Angeles headquarters. The Content Distribution Agreement between MDD and StreamNow was executed in California. Ogilvie formed and operated MDD from Beverly Hills. The unauthorized exploitation of Aurelius's intellectual property was conceived, planned, and executed within this district. A substantial part of the events and omissions giving rise to the claim occurred here, and venue is independently proper under § 1391(b)(2).
Either subsection standing alone would support venue in the Central District of California. Together, they provide an unassailable alternative basis for venue in this forum.
C. Los Angeles Division Specifically
The Central District of California is divided into multiple divisions. StreamNow's headquarters at 3400 Wilshire Boulevard, Los Angeles, California 90010, and MDD's address at 8912 Burton Way, Beverly Hills, California 90211, are both located within the Los Angeles Division of the Central District.
Local Rule 2-1 of the Central District of California governs divisional assignment. Under that rule, cases are assigned to the division in which the events giving rise to the claims principally occurred. Because the principal events in this case — StreamNow's infringing activities, MDD's fraudulent licensing operations, and Ogilvie's unauthorized conduct — all occurred within the geographic boundaries of the Los Angeles Division, assignment to that division is appropriate and expected.
There is no question that the Los Angeles Division is the proper division within the Central District for this action.
D. Considerations Regarding FAST Channel Sublicensees
Our investigation has identified four FAST channel sublicensees that received Aurelius content through StreamNow's platform:
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
These entities are not proposed as defendants in the initial complaint. However, I note for completeness that if any of these entities are later joined as defendants, venue in the Central District of California would remain proper under 28 U.S.C. § 1391(b)(2), as a substantial part of the events giving rise to the claims occurred in this district regardless of where the sublicensees are located. The sublicensees' receipt and further distribution of the infringing content, while relevant to the scope of infringement and damages, does not alter the fact that the originating infringing conduct — the unauthorized licensing and distribution — emanated from the Central District.
The two foreign sublicensees — Velvet Stream Partners, LP (Canada) and Pacific Lantern Digital Pty Ltd (Australia) — raise additional considerations regarding international service of process, the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents, and cross-border enforcement of judgments. Those issues are beyond the scope of this jurisdictional and venue memorandum and would need to be addressed in a separate analysis if joinder of these entities is contemplated.
Recommendation: Focus the initial complaint on StreamNow, MDD, and Ogilvie as the primary defendants. Address the FAST channel sublicensees through separate takedown demands under 17 U.S.C. § 512 and direct cease-and-desist communications. Assess joinder of the domestic sublicensees (Brindoval and BrightLoop) at a later stage based on their compliance with takedown demands and the extent of their independent infringement. Defer joinder of the foreign sublicensees unless their continued infringement warrants the additional complexity and expense of international litigation.
VI. POTENTIAL JURISDICTIONAL CHALLENGES AND COUNTERARGUMENTS
While I do not anticipate any viable jurisdictional challenge from any defendant, I address below the most likely arguments that Defendants' counsel might raise and explain why each would fail.
A. StreamNow's Potential Forum Non Conveniens Argument
StreamNow might argue that the Central District of California is an inconvenient forum and that the case should be dismissed on forum non conveniens grounds. This argument is extremely unlikely to succeed, for several reasons.
First, forum non conveniens is an extraordinary remedy that requires the movant to demonstrate that an adequate alternative forum exists and that the balance of private and public interest factors strongly favors dismissal. See Piper Aircraft Co. v. Reyno, 454 U.S. 235, 255–61 (1981); Dole Food Co. v. Watts, 303 F.3d 1104, 1118 (9th Cir. 2002). Here, no adequate alternative forum has been identified. The United Kingdom — Aurelius's home jurisdiction — is not an appropriate forum for U.S. copyright infringement claims, which arise exclusively under federal law. StreamNow's state of incorporation (Delaware) has no meaningful connection to the underlying facts and would not be a more convenient forum for any party.
Second, the Central District of California is the most convenient forum for all parties, witnesses, and evidence. StreamNow is headquartered here. Its principal officers — Derek Calloway (CEO), Priya Menon (COO), Sandra Yee (VP Content Acquisition), and Tobias Rennert (General Counsel) — are all based in Los Angeles. Its outside counsel, Grantham Roth & Pearce LLP, is in Los Angeles. MDD and Ogilvie are in Beverly Hills. Aurelius's U.S. subsidiary, AMA, is in Los Angeles. The documentary and electronic evidence is concentrated in Los Angeles. No party or witness would be inconvenienced by litigating in this forum.
Third, the Ninth Circuit has consistently held that a defendant who is "at home" in the forum state carries a particularly heavy burden in seeking dismissal on forum non conveniens grounds. StreamNow, as a company headquartered in the Central District, cannot credibly argue that this forum is inconvenient.
A forum non conveniens motion by StreamNow would be meritless and would likely be denied summarily.
B. StreamNow's Potential Motion to Transfer Under 28 U.S.C. § 1404(a)
StreamNow might alternatively seek a transfer of venue under 28 U.S.C. § 1404(a), which permits transfer "[f]or the convenience of parties and witnesses, in the interest of justice" to any other district where the case "might have been brought." This motion would also fail.
The private interest factors under § 1404(a) — including the convenience of the parties, the convenience of witnesses, the relative ease of access to evidence, and the availability of compulsory process — overwhelmingly favor the Central District. All key parties are in the Los Angeles area. The critical witnesses (StreamNow executives, Ogilvie, AMA personnel) are in Los Angeles. The documentary evidence is maintained in Los Angeles. No plausible transferee district offers superior convenience.
The public interest factors — including court congestion, the local interest in resolving local controversies, and the familiarity of the forum with the applicable law — likewise favor the Central District. This dispute involves Los Angeles-based companies and individuals engaging in allegedly infringing conduct directed from Los Angeles. The Central District has a strong local interest in adjudicating this controversy.
Delaware — StreamNow's state of incorporation — is the only other district where venue might technically be proper (based on StreamNow's corporate domicile), but it has no meaningful connection to the facts and would be less convenient for every party, including StreamNow itself. A motion to transfer to Delaware would be contrary to StreamNow's own interests and those of all other parties.
No plausible basis for transfer exists.
C. Challenges to Personal Jurisdiction
As analyzed in detail in Section IV above, all three defendants are subject to general jurisdiction in California. StreamNow is headquartered in Los Angeles; MDD is a California LLC based in Beverly Hills; and Ogilvie is a California domiciliary. No viable challenge to personal jurisdiction exists.
StreamNow, in particular, cannot credibly argue that it lacks minimum contacts with California. The company's headquarters, principal officers, operational staff, and outside counsel are all located in California. Its content acquisition activities — including the Content Distribution Agreement with MDD — were directed from California. StreamNow's connections to the forum are not merely sufficient; they are paradigmatic of the contacts that give rise to general jurisdiction under Daimler.
MDD and Ogilvie face an equally futile jurisdictional challenge. MDD is a California LLC with its only known address in Beverly Hills, and Ogilvie is a California domiciliary who conducted all relevant activities within the state. Any motion to dismiss for lack of personal jurisdiction by either of these defendants would be frivolous.
I do not anticipate that any defendant will raise a personal jurisdiction challenge, but if such a challenge is raised, it will be readily defeated.
D. Standing Considerations
While not strictly a jurisdictional issue in the Article III sense, standing to bring copyright infringement claims requires that the plaintiff be the legal or beneficial owner of an exclusive right under the copyright. See 17 U.S.C. § 501(b).
Aurelius Global Media Group PLC, as the registered copyright owner of the 217 works at issue, has standing to bring copyright infringement claims. The Lexington IP Services search completed January 22, 2026, confirmed that all 217 works are registered with the United States Copyright Office in the name of Aurelius or its predecessor entities, with proper assignments recorded.
Aurelius Media Americas, Inc. may also have standing as a co-owner or exclusive licensee with respect to certain titles, depending on the specific registration and chain of title for each work. The chain-of-title memorandum (Matter No. 1017-00003, forthcoming) will address this issue in detail on a title-by-title basis.
Recommendation: Name Aurelius Global Media Group PLC as the primary plaintiff. If the chain-of-title analysis reveals that AMA holds the relevant registration or exclusive license for specific titles, join AMA as a co-plaintiff for those titles. As discussed in Section III.C above, the addition of AMA as a co-plaintiff may affect the availability of diversity jurisdiction as an alternative basis, but this is immaterial given the strength of the § 1338(a) jurisdictional basis.
VII. RECOMMENDATIONS
Based on the foregoing analysis, I recommend the following:
A. Forum Selection
Aurelius should file its copyright infringement action in the United States District Court for the Central District of California, Los Angeles Division. This forum provides the strongest jurisdictional basis, the most convenient venue for all parties, and the greatest strategic advantages for Aurelius. No other forum offers a comparable combination of jurisdictional certainty, geographic convenience, and procedural efficiency. The Central District of California's familiarity with complex intellectual property disputes, its well-developed local rules for such cases, and the concentration of relevant parties, witnesses, and evidence in the Los Angeles area make it the optimal forum for this action.
B. Jurisdictional Allegations in Complaint
The complaint should contain the following jurisdictional and venue allegations:
1. Federal Subject Matter Jurisdiction: Plead 28 U.S.C. § 1338(a) as the primary basis for subject matter jurisdiction, identifying the claims as arising under the United States Copyright Act, 17 U.S.C. §§ 106 and 501.
2. Supplemental Jurisdiction: Plead 28 U.S.C. § 1367 as the basis for jurisdiction over the California Business and Professions Code § 17200 unfair competition claim and the tortious interference with prospective economic advantage claim, alleging that these state-law claims arise from the same case or controversy as the federal copyright claims.
3. Diversity Jurisdiction (Alternative): If Aurelius is the sole named plaintiff, reference 28 U.S.C. § 1332(a)(2) as an alternative jurisdictional basis, alleging that the action is between a citizen of a foreign state (Aurelius, United Kingdom) and citizens of a State (StreamNow — Delaware/California; MDD — California; Ogilvie — California), and that the amount in controversy exceeds $75,000 exclusive of interest and costs.
4. Venue: Allege venue under 28 U.S.C. § 1400(a) as the primary basis, and alternatively under 28 U.S.C. § 1391(b)(1) (all defendants reside in California and in the Central District) and § 1391(b)(2) (substantial part of the events occurred in the Central District).
5. Personal Jurisdiction: Allege personal jurisdiction over each defendant separately, citing both general jurisdiction (domicile, headquarters, or principal place of business in California) and specific jurisdiction (forum-related infringing conduct, purposeful direction of activities toward the forum, and the reasonableness of exercising jurisdiction).
C. Service of Process
Service of process should be effectuated as follows:
StreamNow Holdings, Inc.: Serve via StreamNow's registered agent, Capitol Registered Agents, Inc., 1209 Orange Street, Wilmington, Delaware 19801, pursuant to Federal Rule of Civil Procedure 4(h)(1)(B), which permits service on a corporation by delivering a copy of the summons and complaint to an officer, a managing or general agent, or any agent authorized by appointment or by law to receive service of process. Alternatively, StreamNow may be served through its General Counsel, Tobias Rennert, at StreamNow's headquarters, 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010, pursuant to Federal Rule of Civil Procedure 4(h)(1)(A), which incorporates state law methods of service, including California Code of Civil Procedure § 416.10 (service on a corporation by delivering to a person designated as agent for service or to the president, other head of the corporation, vice president, secretary, assistant secretary, treasurer, assistant treasurer, controller, or general manager).
Meridian Digital Distributors, LLC: Serve Franklin Ogilvie, as MDD's sole member and manager, at 8912 Burton Way, Suite 200, Beverly Hills, California 90211, pursuant to Federal Rule of Civil Procedure 4(h)(1)(A), incorporating California Code of Civil Procedure § 416.40 (service on an unincorporated association by delivering to the person designated as agent for service of process or, if none, to the president or other head of the association, a vice president, a secretary or assistant secretary, a treasurer or assistant treasurer, a general manager, or a person authorized to receive service on behalf of the association).
Franklin Ogilvie (Individually): Serve by personal service at Ogilvie's known address in the Beverly Hills area, pursuant to Federal Rule of Civil Procedure 4(e), which permits service by following state law for serving a summons in an action brought in courts of general jurisdiction in the state where the district court is located (California) or in the state where service is made. Under California Code of Civil Procedure § 415.10, an individual may be served by personal delivery of a copy of the summons and complaint to the person to be served. If personal service cannot be accomplished after reasonable diligence, substituted service under California Code of Civil Procedure § 415.20(b) is available.
I recommend serving all three defendants simultaneously to minimize the risk of informal coordination among defendants in advance of the responsive pleading deadline.
VIII. CONCLUSION
The United States District Court for the Central District of California, Los Angeles Division, is the proper and optimal forum for Aurelius Global Media Group PLC's copyright infringement action against StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie.
Subject matter jurisdiction is firmly established under 28 U.S.C. § 1338(a), which grants federal courts original and exclusive jurisdiction over claims arising under the Copyright Act. Supplemental jurisdiction under 28 U.S.C. § 1367 extends the court's jurisdiction to the state-law claims for unfair business practices under California Business and Professions Code § 17200 and tortious interference with prospective economic advantage, both of which arise from the same common nucleus of operative fact as the federal copyright claims. Diversity jurisdiction under 28 U.S.C. § 1332(a)(2) provides an additional alternative basis if Aurelius is the sole named plaintiff.
Personal jurisdiction exists over all three defendants on both general and specific jurisdiction grounds. StreamNow is headquartered in Los Angeles and is "at home" in California under Daimler. MDD is a California LLC with its sole address in Beverly Hills. Ogilvie is a California domiciliary who conducted all relevant activities within the state. No defendant can credibly contest personal jurisdiction in this forum.
Venue is proper under the copyright-specific venue statute, 28 U.S.C. § 1400(a), as all defendants reside in the Central District. Venue is independently proper under the general venue statute, 28 U.S.C. § 1391(b)(1) and (b)(2), as all defendants reside in California and a substantial part of the events giving rise to the claims occurred within the Central District.
No viable jurisdictional or venue challenge is anticipated from any defendant. Any motion to dismiss for lack of jurisdiction, motion to transfer, or motion to dismiss on forum non conveniens grounds would lack merit and would be denied.
I recommend proceeding with the preparation of the draft complaint for filing in this forum. I am available to discuss any aspect of this analysis and to assist with the drafting of the jurisdictional and venue allegations for the complaint.
•
APPENDIX — REFERENCED MATERIALS
The following documents are referenced in this memorandum and are either attached, forthcoming, or available upon request:
1. Draft Complaint — Aurelius Global Media Group PLC v. StreamNow Holdings, Inc. et al. (forthcoming; to be prepared upon approval of forum selection).
2. Chain-of-Title Memorandum — Matter No. 1017-00003 (forthcoming; will address copyright ownership, registration chain, and standing for each of the 217 titles at issue).
3. Copyright Registration Summary Report — Prepared by Lexington IP Services; search completed January 22, 2026 (confirms registration status of all 217 titles, including registration numbers, effective dates, and timeliness determinations for statutory damages eligibility).
4. CipherTrace Forensic Analysis Summary — (forthcoming; will address digital forensic findings regarding StreamNow's ingestion and distribution of Aurelius content, metadata analysis, and attribution of unauthorized access to MDD/Ogilvie).
5. Cal. Bus. & Prof. Code § 17200 Supplemental Claim Memorandum — (forthcoming; will address Copyright Act preemption analysis and viability of the § 17200 claim).
Prepared by Omar Siddiqui, Associate. Please direct any questions or comments to the undersigned at osiddiqui@[firm].com or extension 4217.

MEMORANDUM

MATTER NO.: 1017-00003

I. EXECUTIVE SUMMARY

II. FACTUAL BACKGROUND RELEVANT TO JURISDICTION AND VENUE

III. SUBJECT MATTER JURISDICTION

IV. PERSONAL JURISDICTION

V. VENUE ANALYSIS

VI. POTENTIAL JURISDICTIONAL CHALLENGES AND COUNTERARGUMENTS

VII. RECOMMENDATIONS

VIII. CONCLUSION

Record

Parties

Dates

Amounts