1017-00003 · Aurelius Global Media Group · Litigation Readiness

draft-complaint-aurelius-v-streamnow.docx DOCUMENT Litigation

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION

Draft Date: March 10, 2026

Plaintiffs Aurelius Global Media Group PLC ("Aurelius" or "AGMG") and Aurelius Media Americas, Inc. ("AMA" and, together with AGMG, "Plaintiffs"), by and through their undersigned attorneys, Calderwood & Harkness LLP, file this Complaint against Defendants StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie ("Ogilvie" and, together with StreamNow and MDD, "Defendants"), and allege as follows:

I. INTRODUCTION

1. This is an action for copyright infringement under 17 U.S.C. §§ 106 and 501 arising from the unauthorized reproduction, distribution, and public performance of 217 copyrighted audiovisual works (the "Works") owned by Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. This action also asserts claims for contributory copyright infringement, inducement of copyright infringement, unfair business practices under California Business and Professions Code § 17200 et seq., and tortious interference with prospective economic advantage.

2. Defendant StreamNow Holdings, Inc. operated a streaming media "super-aggregator" platform that ingested and exploited Plaintiffs' Works without authorization for a period of approximately twenty-two (22) months, from approximately April 1, 2024 through January 31, 2026. During this period, StreamNow made Plaintiffs' valuable copyrighted content available to its subscribers in fourteen countries, reproduced and stored copies of the Works on its servers and content delivery networks, distributed the Works to end users, publicly performed the Works via streaming, and sublicensed bundles containing the Works to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators — all without any authorization, license, or consent from Plaintiffs.

3. StreamNow purportedly obtained the right to exploit Plaintiffs' content through a sublicense from Defendant Meridian Digital Distributors, LLC, a sham intermediary entity operated by Defendant Franklin Ogilvie. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc. whose employment was terminated on June 30, 2021 following an internal investigation that revealed unauthorized access to Aurelius's content management systems. Ogilvie had no authority whatsoever to license any Aurelius content, and MDD has never been an authorized distributor of Aurelius. The purported sublicense from MDD to StreamNow is void and of no legal effect as to any Aurelius content.

4. The 217 Works that Defendants exploited without authorization include some of Aurelius's most commercially valuable and culturally significant properties. Among the Works at issue are: (a) the "Meridian" franchise, consisting of six feature films with combined global box office receipts of approximately $1.43 billion; (b) the "Iron Compass" series, Aurelius's highest-rated original dramatic series, encompassing four seasons and forty-eight episodes, averaging 9.2 million viewers per episode in the United Kingdom; and (c) the "Thornfield" period drama catalog, comprising twelve titles and the recipient of seven British Academy of Film and Television Arts ("BAFTA") awards. These properties represent the crown jewels of Aurelius's extensive content library and command premium licensing fees in arm's-length transactions with authorized distributors.

5. StreamNow generated an estimated $38.6 million in revenue directly attributable to the infringing Aurelius content during the twenty-two-month infringement period, comprising subscription revenue, advertising revenue from its ad-supported tier, and sublicensing fees received from FAST channel operators. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a catalog of this size and quality over the relevant time period and in the relevant territories, is estimated at $14.2 million.

6. By this action, Plaintiffs seek actual damages, disgorgement of Defendants' profits attributable to the infringement, statutory damages in the alternative for the 189 timely-registered Works, a permanent injunction prohibiting Defendants from any further exploitation of Plaintiffs' content, impoundment and destruction of all infringing copies, reasonable attorneys' fees and costs, restitution and injunctive relief under California Business and Professions Code § 17200, compensatory damages for tortious interference with prospective economic advantage, and such other and further relief as the Court deems just and proper.

II. THE PARTIES

A. Plaintiffs.

7. Plaintiff Aurelius Global Media Group PLC ("Aurelius" or "AGMG") is a public limited company duly organized and existing under the laws of England and Wales, registered with Companies House under Registration Number 08724561. Aurelius maintains its corporate headquarters at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius's ordinary shares are listed and traded on the Alternative Investment Market ("AIM") of the London Stock Exchange under the ticker symbol "AGLM." In addition, American Depositary Receipts representing Aurelius ordinary shares are traded over-the-counter in the United States.

8. Aurelius is a major international media and entertainment conglomerate with operations spanning content production, acquisition, licensing, distribution, and theatrical exhibition across multiple continents. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). Aurelius owns and administers a content library of over 4,200 film and television titles, spanning multiple genres, languages, and decades. The company is led by Chief Executive Officer Sir Alistair Pemberton and General Counsel Fiona Hartwell.

9. Plaintiff Aurelius Media Americas, Inc. ("AMA") is a corporation duly organized and existing under the laws of the State of Delaware. AMA is a wholly-owned subsidiary of Aurelius Global Media Group PLC. AMA maintains its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA manages Aurelius's content licensing, distribution, and intellectual property enforcement operations throughout the United States and the broader Americas region. AMA holds or administers United States copyrights in the Works at issue on behalf of AGMG, including the copyrights in the 217 Works that are the subject of this action.

B. Defendants.

10. Defendant StreamNow Holdings, Inc. ("StreamNow") is a corporation duly organized and existing under the laws of the State of Delaware, Delaware Division of Corporations File Number 7291843. StreamNow maintains its corporate headquarters and principal place of business at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow's registered agent in Delaware is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.

11. StreamNow operates a streaming media "super-aggregator" platform that bundles content from multiple studios, production companies, and independent distributors into a single subscription-based or advertising-supported interface. StreamNow's platform is available to consumers in fourteen countries, including the United States, Canada, Australia, and eleven additional territories. In addition to its direct-to-consumer streaming service, StreamNow sublicenses content bundles to third-party multichannel video programming distributor ("MVPD") operators and FAST channel operators.

12. StreamNow is privately held. Approximately sixty-two percent (62%) of StreamNow's fully diluted equity is owned by Pinnacle Ventures Fund III, LP, a venture capital fund whose general partner is Pinnacle Ventures Management III, LLC (managing partner: Howard Cheng), headquartered at 101 California Street, Suite 3500, San Francisco, California 94111. Pinnacle Ventures Fund III, LP invested $145 million in StreamNow's Series C financing round, which closed in June 2022. StreamNow's estimated revenue for the fiscal year ended December 31, 2025 was approximately $312 million.

13. StreamNow's senior leadership includes Chief Executive Officer and Co-Founder Derek Calloway, Chief Operating Officer and Co-Founder Priya Menon, General Counsel Tobias Rennert, and Vice President of Content Acquisition Sandra Yee. On information and belief, StreamNow's outside litigation counsel is the firm of Grantham Roth & Pearce LLP, located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071 (lead partner: Victoria Langford; associate: Brian Matsuda).

14. Defendant Meridian Digital Distributors, LLC ("MDD") is a limited liability company organized and existing under the laws of the State of California, California Secretary of State File Number 202115729430. MDD's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD was formed in late 2021 by Defendant Franklin Ogilvie. Ogilvie is MDD's sole member and manager. As of February 2026, MDD's status with the California Secretary of State is listed as "Active." MDD purported to license Aurelius content to StreamNow but had no authority, license, or right of any kind to do so.

15. Defendant Franklin Ogilvie ("Ogilvie") is an individual residing in or around Los Angeles, California. Ogilvie is the sole member and manager of Meridian Digital Distributors, LLC. Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. Ogilvie's employment was terminated following an internal investigation that revealed unauthorized access to Aurelius's proprietary content management systems. Upon his termination, Ogilvie executed a separation agreement dated June 30, 2021, which contained, among other provisions: (i) a non-compete clause; (ii) a non-solicitation clause; and (iii) an explicit prohibition on the use of any Aurelius intellectual property. Ogilvie formed MDD in late 2021, shortly after his departure from Aurelius, and thereafter used MDD as a vehicle to exploit Aurelius's copyrighted content without authorization.

III. JURISDICTION AND VENUE

A. Subject Matter Jurisdiction

16. This Court has original subject matter jurisdiction over Plaintiffs' federal copyright infringement claims (Counts I, II, and III) pursuant to 28 U.S.C. § 1331 (federal question jurisdiction) and 28 U.S.C. § 1338(a) (jurisdiction over actions arising under the Copyright Act).

17. This Court has supplemental jurisdiction over Plaintiffs' state law claims (Counts IV and V) pursuant to 28 U.S.C. § 1367(a), because those claims are so related to the federal copyright claims within the original jurisdiction of this Court that they form part of the same case or controversy under Article III of the United States Constitution. Specifically, Plaintiffs' state law claims for unfair business practices and tortious interference with prospective economic advantage arise from the same nucleus of operative facts as the federal copyright infringement claims — namely, Defendants' unauthorized exploitation of Plaintiffs' copyrighted Works through the sham MDD sublicensing arrangement.

B. Personal Jurisdiction

18. This Court has personal jurisdiction over Defendant StreamNow Holdings, Inc. because StreamNow is headquartered in and maintains its principal place of business in Los Angeles, California, which is within the Central District of California. StreamNow conducts continuous and systematic business operations within this District and within the State of California.

19. This Court has personal jurisdiction over Defendant Meridian Digital Distributors, LLC because MDD is a California limited liability company with its registered address in Beverly Hills, California, which is within the Central District of California. MDD was organized under the laws of the State of California and, on information and belief, conducts business within this District and within the State of California.

20. This Court has personal jurisdiction over Defendant Franklin Ogilvie because Ogilvie resides in or around Los Angeles, California, which is within the Central District of California. Ogilvie conducted the acts giving rise to this action, including the formation of MDD, the negotiation and execution of the purported Content Distribution Agreement with StreamNow, and the delivery of infringing content to StreamNow, within the Central District of California and within the State of California.

21. Each Defendant has sufficient minimum contacts with the State of California and with this District such that the exercise of personal jurisdiction over each Defendant comports with due process and is consistent with the requirements of the California long-arm statute, Cal. Code Civ. Proc. § 410.10.

C. Venue.

22. Venue is proper in this District under 28 U.S.C. § 1400(a), which provides that civil actions arising under the copyright laws may be instituted in the district in which the defendant or the defendant's agent resides or may be found. All Defendants reside in, are domiciled in, or have their principal places of business within the Central District of California.

23. Venue is also proper under 28 U.S.C. § 1391(b)(1) and (b)(2), as all Defendants reside in this judicial district, and a substantial part of the events or omissions giving rise to the claims asserted herein occurred within this District. Specifically, the negotiation and execution of the purported Content Distribution Agreement between MDD and StreamNow, the ingestion and streaming of the infringing content on StreamNow's platform, and the sublicensing of the infringing content to FAST channel operators all occurred in whole or in substantial part within the Central District of California.

IV. FACTUAL ALLEGATIONS

A. Aurelius and Its Copyrighted Works

24. Aurelius Global Media Group PLC is a leading international media and entertainment conglomerate headquartered in London, United Kingdom. With a storied history spanning multiple decades, Aurelius has built one of the most valuable and diverse content libraries in the entertainment industry, comprising over 4,200 film and television titles. The library includes globally recognized franchises, critically acclaimed dramatic works, award-winning documentaries, and commercially successful genre films, spanning a wide range of creative expression.

25. Among the most commercially valuable and culturally significant properties in the Aurelius library are the following, each of which is at issue in this action:

(a) The "Meridian" Franchise: A series of six interconnected feature films in the science fiction and action-adventure genres, produced between 2011 and 2023, with combined worldwide theatrical box office receipts of approximately $1.43 billion. The Meridian franchise is one of the highest-grossing original film franchises in Aurelius's history and commands premium licensing fees across all distribution windows.

(b) The "Iron Compass" Series: Aurelius's highest-rated original dramatic television series, comprising four seasons and forty-eight individual episodes. The series, a critically acclaimed espionage thriller set during the Cold War, averaged 9.2 million viewers per episode in the United Kingdom during its initial broadcast run and has been widely licensed to international broadcasters and streaming platforms. The series has received numerous industry awards and nominations and remains a cornerstone of Aurelius's television content strategy.

(c) The "Thornfield" Period Drama Catalog: A collection of twelve distinguished period drama titles — encompassing feature films and limited television series — produced over a span of approximately fifteen years. The Thornfield catalog has been the recipient of seven BAFTA awards and has garnered international acclaim for its production values, performances, and historical authenticity. The catalog is a prestige property that anchors Aurelius's licensing negotiations with premium content buyers worldwide.

26. Aurelius, through its wholly-owned subsidiary Aurelius Media Americas, Inc., owns all right, title, and interest in and to the copyrights in the 217 audiovisual Works at issue in this action (collectively, the "Works"). The 217 Works comprise 142 feature films and 75 television series encompassing a total of 1,038 individual episodes.

27. Aurelius licenses its content to authorized streaming platforms, broadcast networks, theatrical exhibitors, and content distributors worldwide through carefully negotiated licensing agreements. These agreements are managed by Aurelius's Senior Vice President of Content Licensing and Distribution, Raj Anantharam, and its Head of Digital Rights Enforcement, Lena Kowalski, in coordination with AMA's licensing team. Aurelius employs a sophisticated windowing and territorial licensing strategy designed to maximize the value of its content across distribution platforms, geographic markets, and release windows. The unauthorized availability of Aurelius content on unlicensed platforms directly undermines this strategy and causes substantial economic harm to Aurelius's licensing program.

B. Copyright Registrations

28. Of the 217 Works at issue in this action, 189 Works have valid and timely United States copyright registrations. These 189 registrations were obtained within three months of the date of first publication of each respective Work, or prior to the commencement of Defendants' infringement, thereby satisfying the registration timing requirements for eligibility for statutory damages and attorneys' fees under 17 U.S.C. §§ 412, 504(c), and 505.

29. The remaining 28 Works have valid United States copyright registrations that post-date the commencement of Defendants' infringement. These 28 registrations were obtained between May 2024 and October 2025. Although these registrations satisfy the jurisdictional prerequisite for suit under 17 U.S.C. § 411(a), the Works covered by these registrations are eligible only for an award of actual damages and infringer's profits under 17 U.S.C. § 504(b), and not for statutory damages or attorneys' fees.

30. All 217 copyright registrations were verified by Lexington IP Services, Inc. (Marissa Chung, Director of Copyright Research) through a comprehensive search of the records maintained by the United States Copyright Office. That search was completed on January 22, 2026 and confirmed the validity and currency of each registration.

31. A complete list of the 217 Works, together with their respective titles, types (feature film or television series), number of episodes (for television series), United States Copyright Registration numbers, registration dates, dates of first publication, registration status (timely or late), and registrant entity, is attached hereto as Exhibit A and incorporated herein by reference.

C. Franklin Ogilvie and Meridian Digital Distributors, LLC

32. Defendant Franklin Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. In that capacity, Ogilvie was responsible for assisting with the administration of content licensing agreements in the Americas region and had access to Aurelius's proprietary content management systems, including databases of title metadata, licensing terms, and distribution schedules.

33. Ogilvie's employment at Aurelius Media Americas was terminated effective June 30, 2021 following an internal investigation conducted by AMA's Human Resources and Legal departments. The investigation revealed that Ogilvie had engaged in unauthorized access to Aurelius's content management systems, including accessing files, databases, and systems beyond the scope of his authorized role and responsibilities.

34. On June 30, 2021, in connection with the termination of his employment, Ogilvie executed a separation agreement with Aurelius Media Americas, Inc. The separation agreement contained, among other material provisions: (i) a non-compete clause prohibiting Ogilvie from engaging in competitive activities with Aurelius for a specified period following the termination of his employment; (ii) a non-solicitation clause prohibiting Ogilvie from soliciting Aurelius's clients, customers, or business partners; and (iii) an explicit prohibition on the use, reproduction, distribution, or exploitation of any Aurelius intellectual property, including copyrighted content, trade secrets, proprietary data, and confidential business information.

35. In late 2021, approximately five months after his departure from Aurelius, Ogilvie formed Meridian Digital Distributors, LLC as a California limited liability company (California Secretary of State File Number 202115729430). Ogilvie registered himself as the sole member and manager of MDD. The entity's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

36. Aurelius has never granted MDD any license, sublicense, distribution agreement, letter of authorization, or any other form of permission or authority to reproduce, distribute, publicly perform, sublicense, or otherwise exploit any Aurelius-owned content. MDD has never been an authorized distributor of Aurelius. No officer, director, employee, or agent of Aurelius or AMA has ever authorized MDD or Ogilvie to act on Aurelius's behalf in connection with any content licensing or distribution transaction.

37. Despite the foregoing, Ogilvie, acting through MDD, falsely represented to StreamNow — and, on information and belief, potentially to other entities — that MDD held valid distribution rights to Aurelius content. These representations were materially false and were made in violation of Ogilvie's separation agreement and in furtherance of a deliberate scheme to misappropriate and exploit Aurelius's valuable copyrighted Works for Ogilvie's personal financial benefit.

D. The MDD–StreamNow Content Distribution Agreement

38. On or about March 15, 2024, Meridian Digital Distributors, LLC and StreamNow Holdings, Inc. executed a purported "Content Distribution Agreement" (the "MDD–StreamNow Agreement"). On information and belief, the MDD–StreamNow Agreement purported to grant StreamNow certain rights to reproduce, distribute, and publicly perform a catalog of more than 350 titles, including the 217 Aurelius Works at issue in this action.

39. Sandra Yee, StreamNow's Vice President of Content Acquisition, acknowledged in an email communication dated November 3, 2025 — sent in response to an inquiry from Raj Anantharam, Aurelius's Senior Vice President of Content Licensing and Distribution — that StreamNow obtained the Aurelius content through a sublicense from MDD. Yee's email stated, in substance, that StreamNow's rights to the Aurelius titles were derived from the Content Distribution Agreement with MDD and that StreamNow understood MDD to be an authorized distributor of the content.

40. MDD had no authority to grant StreamNow or any other party any rights in the Aurelius Works. The MDD–StreamNow Agreement is therefore void and of no legal effect as to any Aurelius content. MDD could not convey rights that it did not possess, and StreamNow acquired no valid rights to the Aurelius Works through the MDD–StreamNow Agreement.

41. StreamNow failed to conduct reasonable due diligence regarding MDD's purported authority to license the Aurelius Works. Had StreamNow undertaken even minimal due diligence — such as contacting Aurelius or AMA directly, reviewing publicly available information about MDD's sole member and his prior employment at Aurelius, or verifying the chain of title for a catalog of 217 titles from a major international studio — StreamNow would have discovered that MDD had no authority to license Aurelius content. The fact that MDD's sole member and manager, Franklin Ogilvie, was a recently terminated employee of Aurelius Media Americas, Inc. was a readily ascertainable fact and should have served as a significant red flag warranting heightened scrutiny of MDD's claimed licensing authority. StreamNow's failure to conduct such due diligence was, at a minimum, reckless and reflects a deliberate indifference to the rights of content owners.

E. StreamNow's Unauthorized Exploitation of the Works

42. Beginning on or about April 1, 2024, StreamNow ingested the 217 Aurelius Works into its platform content library. The ingestion process involved receiving digital master files of the Works from MDD, encoding or transcoding the files into formats suitable for streaming delivery, and uploading the files to StreamNow's servers and content delivery networks.

43. From approximately April 1, 2024 through at least January 31, 2026 — a period of approximately twenty-two (22) months — StreamNow made the 217 Works available for streaming to its subscribers in the United States, Canada, Australia, and eleven additional international territories, for a total of fourteen countries.

44. StreamNow reproduced the Works within the meaning of 17 U.S.C. § 106(1) by making and storing multiple copies of the Works on its servers, content delivery networks, and associated storage infrastructure. Each reproduction was made without authorization from Plaintiffs.

45. StreamNow distributed the Works within the meaning of 17 U.S.C. § 106(3) by transmitting copies of the Works to end users via its streaming platform. Each such transmission constituted a distribution of the Works to the public without authorization from Plaintiffs.

46. StreamNow publicly performed the Works within the meaning of 17 U.S.C. § 106(4) by streaming the Works to its subscribers. Each streaming transmission constituted a public performance of the Works without authorization from Plaintiffs.

47. The unauthorized exploitation continued unabated for the full twenty-two-month period, during which time StreamNow's subscriber base accessed the Aurelius Works through both StreamNow's subscription tier and its ad-supported (AVOD) tier. StreamNow featured a number of the Aurelius titles prominently in its platform interface, including in curated recommendation carousels, editorial playlists, and algorithmic recommendations, thereby actively directing subscriber attention to the infringing content.

48. StreamNow is not a passive hosting service or mere conduit for content. StreamNow exercises editorial control over its content catalog, including the selection of titles for inclusion on its platform, the curation and organization of content within its user interface, the establishment of pricing tiers and subscription models, and the determination of geographic availability for individual titles. StreamNow actively negotiates licensing agreements (or purports to negotiate licensing agreements) with content suppliers, sets the terms under which content is made available to consumers, and directly monetizes the content through subscription fees, advertising revenue, and sublicensing arrangements.

F. StreamNow's Sublicensing to FAST Channel Operators

49. In addition to exploiting the Aurelius Works through its own direct-to-consumer streaming platform, StreamNow sublicensed content bundles containing Aurelius titles to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators. On information and belief, these sublicensing arrangements were made pursuant to StreamNow's standard FAST channel distribution agreements, under which StreamNow grants FAST channel operators the right to stream bundled content catalogs on their ad-supported channels in exchange for sublicensing fees and/or revenue-sharing arrangements.

50. The four FAST channel operators to which StreamNow sublicensed bundles containing Aurelius content are:

(a) Brindoval Channel Networks, Inc., a company based in Dallas, Texas;

(b) BrightLoop Media, LLC, a company based in Miami, Florida;

(d) Pacific Lantern Digital Pty Ltd, a company based in Sydney, New South Wales, Australia.

51. Each of these FAST channel operators further reproduced, distributed, and publicly performed the Aurelius Works without Aurelius's authorization, extending the reach of the unauthorized exploitation beyond StreamNow's own platform to additional consumer-facing distribution channels. Aurelius never authorized StreamNow to sublicense its content to any third party, and StreamNow had no right to grant any sublicenses in Aurelius content because it had no valid license itself.

G. Revenue Attribution and Damages

52. Plaintiffs retained CipherTrace Analytics, LLC ("CipherTrace"), a digital forensic analytics firm, to identify and quantify StreamNow's revenue attributable to the infringing Aurelius content. Dr. Nathan Frey served as the engagement lead for CipherTrace's analysis. CipherTrace's analysis drew upon publicly available data, industry benchmarking data, and preliminary information obtained through Plaintiffs' pre-filing investigation, and yielded the following revenue attributions:

(a) Subscription Revenue: Subscription revenue allocable to the Aurelius titles was estimated at $22.4 million, based on CipherTrace's refined viewership share model with premium-tier weighting. This model allocates subscription revenue among individual titles based on their proportionate share of total viewership hours, adjusted to reflect the premium value of high-profile franchise titles (such as the Meridian franchise and Iron Compass series) that disproportionately drive subscriber acquisition and retention.

(b) Advertising Revenue (AVOD Tier): Advertising revenue allocable to the Aurelius titles was estimated at $9.7 million, based on ad impression data associated with the viewing of Aurelius content on StreamNow's ad-supported tier.

(c) Sublicensing Fees: Sublicensing fees received by StreamNow from FAST channel operators for content bundles containing Aurelius titles were estimated at $6.5 million, based on StreamNow's reported sublicensing revenue and the proportionate share of Aurelius titles within the sublicensed bundles.

(d) Total Attributable Revenue: The total revenue attributable to StreamNow's unauthorized exploitation of the Aurelius Works was estimated at $38.6 million.

53. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a catalog of similar size, quality, and market appeal over a period of twenty-two months in the relevant territories, is estimated at $14.2 million. This estimate is based on Aurelius's existing licensing agreements with authorized platforms for comparable content catalogs, adjusted for the specific titles, territories, and time period at issue.

54. Plaintiffs also retained Hargrove Economic Consulting Group, LLC ("Hargrove"), to prepare a preliminary damages analysis. Dr. Elena Vasquez of Hargrove served as the lead consultant. Dr. Vasquez's analysis estimates net recoverable damages of $41.3 million, comprising Plaintiffs' actual damages (lost licensing revenue) plus StreamNow's infringer's profits, with appropriate apportionment to avoid double-counting in accordance with 17 U.S.C. § 504(b). Plaintiffs reserve the right to supplement and revise this damages analysis as additional information becomes available through discovery.

55. In the alternative, for the 189 Works with timely copyright registrations, Plaintiffs are entitled to elect statutory damages in lieu of actual damages and profits. Under 17 U.S.C. § 504(c)(2), where infringement is committed willfully, the Court may award statutory damages of up to $150,000 per work infringed. For the 189 timely-registered Works, the potential aggregate statutory damages award is up to $28,350,000 (189 × $150,000). For the remaining 28 late-registered Works, Plaintiffs' recovery is limited to actual damages and infringer's profits. Plaintiffs note that the combined total across all 217 Works, assuming willful infringement, yields a potential statutory component of up to $28,350,000 for the 189 timely-registered Works, supplemented by actual damages for the remaining 28 Works.

H. Discovery of the Infringement

56. On October 15, 2025, Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, discovered that numerous Aurelius titles were streaming on the StreamNow platform without authorization. Kowalski identified the presence of Aurelius-owned content during a routine content monitoring sweep of digital streaming platforms conducted as part of Aurelius's ongoing intellectual property enforcement program.

57. On October 22, 2025, Kowalski escalated the matter to Fiona Hartwell, General Counsel of Aurelius Global Media Group PLC. Upon receiving Kowalski's report, Hartwell authorized the commencement of a formal internal investigation to determine the scope and source of the unauthorized distribution.

58. On November 3, 2025, Sandra Yee, StreamNow's Vice President of Content Acquisition, responded to an informal inquiry from Raj Anantharam, Aurelius's Senior Vice President of Content Licensing and Distribution, regarding the source of StreamNow's purported rights to the Aurelius content. In her response, Yee stated that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC and indicated that StreamNow considered MDD to be an authorized distributor of the content.

59. On November 18, 2025, Aurelius engaged Bexley Marsh Solicitors LLP, a London-based law firm, to conduct a preliminary legal assessment of the matter, including an evaluation of the jurisdictional and substantive legal issues implicated by the unauthorized distribution.

60. On December 5, 2025, Bexley Marsh Solicitors LLP completed its preliminary assessment and recommended that Aurelius engage United States counsel to pursue the copyright infringement claims arising under U.S. law in a U.S. federal court.

61. On January 8, 2026, Aurelius and AMA contacted Calderwood & Harkness LLP regarding potential representation in connection with the unauthorized exploitation of the Aurelius Works.

62. On January 15, 2026, Marcus Delgado, Partner at Calderwood & Harkness LLP, and Fiona Hartwell, General Counsel of Aurelius, held an initial consultation to discuss the facts, legal theories, and potential claims.

63. On February 12, 2026, Calderwood & Harkness LLP formally opened the engagement under Matter Number 1017-00003 and commenced preparation of this Complaint.

I. DMCA Safe Harbor Does Not Apply

64. StreamNow does not qualify for protection under the safe harbor provisions of Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512.

65. The DMCA safe harbors, including the safe harbor for hosting services under 17 U.S.C. § 512(c) and the safe harbor for information location tools under 17 U.S.C. § 512(d), are available only to "service providers" that function as passive intermediaries in the transmission, storage, or location of user-generated or user-uploaded content. These safe harbors do not extend to entities that actively acquire, curate, license, and monetize copyrighted content as a core element of their business model.

66. StreamNow is not a passive hosting service, internet service provider, or mere intermediary. StreamNow actively curates its content catalog, affirmatively negotiating licenses (or purporting to negotiate licenses) with content suppliers and selectively choosing which titles to include in its platform library. StreamNow exercises editorial control over the selection, organization, and presentation of content on its platform, including the placement of titles in curated recommendation carousels, editorial playlists, and genre categories. StreamNow sets pricing tiers for its subscription and ad-supported services, controls the geographic availability of individual titles across its fourteen-country footprint, and directly monetizes the content through subscription fees, advertising revenue, and sublicensing fees charged to FAST channel operators.

67. StreamNow's active, affirmative, and central role in the acquisition, curation, promotion, and monetization of the infringing content places it squarely outside the scope of the DMCA safe harbor provisions. StreamNow is not entitled to any limitation of liability under Section 512 of the DMCA.

J. StreamNow's Infringement Was Willful

68. StreamNow's infringement of Plaintiffs' copyrights was willful within the meaning of 17 U.S.C. § 504(c)(2). The following facts, individually and collectively, demonstrate the willful nature of StreamNow's infringement:

(a) Sophisticated Operator: StreamNow is a sophisticated content platform operator with substantial experience in the content licensing industry. StreamNow routinely negotiates and executes licensing agreements with major studios, production companies, and independent distributors. StreamNow maintains a dedicated content acquisition department led by a Vice President of Content Acquisition and employs a General Counsel responsible for overseeing the company's legal compliance. StreamNow is therefore well aware of the importance of verifying the chain of title and licensing authority of its content suppliers.

(b) Failure to Conduct Due Diligence: Despite its sophistication and experience, StreamNow failed to conduct reasonable due diligence regarding MDD's authority to license the Aurelius Works. StreamNow did not contact Aurelius or AMA to verify MDD's claimed distribution rights. StreamNow did not request or obtain any documentation establishing MDD's chain of title to the Aurelius content. StreamNow did not investigate the provenance of a catalog of 217 titles from a major international studio that was being offered by a small, recently formed intermediary with no track record in the industry.

(c) Readily Available Red Flags: Franklin Ogilvie's prior employment at Aurelius Media Americas, Inc. and the circumstances of his departure were matters of readily ascertainable public record and industry knowledge. A basic internet search, a review of MDD's corporate filings, or a simple inquiry to Aurelius would have revealed that MDD's sole principal was a former Aurelius employee whose employment had been recently terminated. These facts constituted obvious red flags that should have prompted heightened scrutiny of MDD's claimed licensing authority.

(d) Massive Scale of Infringement: The scale of StreamNow's infringement was massive, encompassing 217 individual titles, including globally recognized franchises and award-winning properties from a major international media conglomerate. The sheer volume and value of the content involved made it implausible that a small, unknown intermediary like MDD would hold legitimate distribution rights to such a catalog.

(e) Prolonged Duration: StreamNow continued to exploit the Aurelius Works for approximately twenty-two months, from April 2024 through January 2026, without ever verifying MDD's authority or contacting Aurelius regarding the source of the content.

(f) Continued Exploitation After Notice: StreamNow continued to exploit the Aurelius Works even after Aurelius raised concerns and inquired about the source of StreamNow's claimed rights. Following the November 3, 2025 email exchange between Sandra Yee and Raj Anantharam, StreamNow did not remove the Aurelius content from its platform or take any steps to investigate MDD's authority. Instead, StreamNow continued to stream the Works and, on information and belief, continued to receive sublicensing revenue from FAST channel operators for bundles containing the Works.

(g) Sublicensing to Third Parties: StreamNow further compounded its infringement by sublicensing the Aurelius content to at least four FAST channel operators, thereby expanding the unauthorized distribution of Plaintiffs' Works to additional platforms and audiences beyond StreamNow's own subscriber base. This sublicensing activity demonstrates StreamNow's aggressive and deliberate exploitation of the infringing content for maximum commercial gain.

K. Impact on Aurelius's Licensing Program

69. StreamNow's unauthorized availability of Aurelius content on its platform and through its FAST channel sublicensees has demonstrably reduced Aurelius's licensing leverage with authorized platforms and distributors. When unauthorized copies of premium content are available to consumers through competing distribution channels at lower price points or through free, ad-supported tiers, the willingness of authorized licensees to pay fair market rates for exclusive or semi-exclusive rights to that content is materially diminished.

70. The unauthorized exploitation has undermined Aurelius's carefully managed windowing and territorial licensing strategies. Aurelius structures its content licensing program to maximize revenue by controlling the timing, geographic scope, and platform exclusivity of content releases. StreamNow's unauthorized distribution of the Works across fourteen countries, without regard for Aurelius's existing territorial licensing commitments or windowing schedules, has created market confusion and eroded the value of Aurelius's content in multiple territories.

71. As a result of Defendants' conduct, Aurelius has suffered harm to its goodwill and reputation as a content licensor. Aurelius's authorized distribution partners and prospective licensees have a reasonable expectation that Aurelius will protect the exclusivity and value of the content it licenses. The unauthorized availability of Aurelius content on StreamNow and through its FAST channel sublicensees undermines confidence in Aurelius's ability to control its own distribution pipeline and protect the rights of its authorized partners.

V. CLAIMS FOR RELIEF

COUNT I.

72. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 71 above as though fully set forth herein.

73. Plaintiffs are the owners of valid copyrights in the 217 Works, as evidenced by the United States Copyright Office registrations identified in Exhibit A attached hereto. Plaintiffs' copyright registrations satisfy the registration requirement for bringing an action for infringement under 17 U.S.C. § 411(a).

74. StreamNow, without authorization, license, or consent from Plaintiffs, has reproduced the 217 Works by making and storing copies on its servers and content delivery networks, in violation of Plaintiffs' exclusive right of reproduction under 17 U.S.C. § 106(1).

75. StreamNow, without authorization, license, or consent from Plaintiffs, has distributed the 217 Works by transmitting copies to end users via its streaming platform, in violation of Plaintiffs' exclusive right of distribution under 17 U.S.C. § 106(3).

76. StreamNow, without authorization, license, or consent from Plaintiffs, has publicly performed the 217 Works by streaming the Works to its subscribers and, through its sublicensing arrangements, to the subscribers of FAST channel operators, in violation of Plaintiffs' exclusive right of public performance under 17 U.S.C. § 106(4).

77. StreamNow's infringement of Plaintiffs' copyrights was willful, as set forth in detail in Paragraphs 68(a) through 68(g) above. StreamNow acted with knowledge of Plaintiffs' copyrights, or with reckless disregard or willful blindness to Plaintiffs' rights, in reproducing, distributing, and publicly performing the Works without obtaining authorization from Plaintiffs or conducting reasonable due diligence regarding the source of MDD's purported licensing authority.

78. As a direct and proximate result of StreamNow's infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation. Plaintiffs are entitled to recover their actual damages and StreamNow's profits attributable to the infringement, pursuant to 17 U.S.C. § 504(b), or, in the alternative, statutory damages for the 189 timely-registered Works, pursuant to 17 U.S.C. § 504(c).

COUNT II.

Contributory Copyright Infringement — Against Meridian Digital Distributors, LLC and Franklin Ogilvie

79. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 78 above as though fully set forth herein.

80. MDD and Ogilvie, with actual knowledge that they had no authority, license, or right to license the Aurelius Works, provided the Works to StreamNow and materially contributed to StreamNow's direct infringement of Plaintiffs' copyrights. Specifically, MDD and Ogilvie supplied the digital master files or access credentials for the 217 Works to StreamNow, entered into the purported Content Distribution Agreement that served as the vehicle for StreamNow's acquisition and exploitation of the Works, and falsely represented to StreamNow that MDD held valid distribution rights to the Works.

81. MDD and Ogilvie knew, or had reason to know, that their purported licensing of the Aurelius Works to StreamNow would result in the unauthorized reproduction, distribution, and public performance of the Works by StreamNow — conduct that constitutes direct copyright infringement, as alleged in Count I above.

82. MDD and Ogilvie induced, caused, and materially contributed to StreamNow's infringing activity by providing the infringing content, facilitating StreamNow's access to and exploitation of the content, and creating the false pretense of licensing authority that enabled StreamNow to ingest and stream the Works on its platform.

83. As a direct and proximate result of MDD's and Ogilvie's contributory infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation.

COUNT III.

Inducement of Copyright Infringement — Against Meridian Digital Distributors, LLC and Franklin Ogilvie

84. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 83 above as though fully set forth herein.

85. MDD and Ogilvie actively induced StreamNow's infringement of Plaintiffs' copyrights by affirmatively representing to StreamNow that MDD held valid distribution rights to the Aurelius Works and by entering into the Content Distribution Agreement dated on or about March 15, 2024, pursuant to which MDD purported to grant StreamNow the right to reproduce, distribute, and publicly perform the Aurelius Works.

86. MDD and Ogilvie acted with the specific intent to cause StreamNow to infringe Plaintiffs' copyrights, or, at a minimum, with actual knowledge that copyright infringement would be a foreseeable and substantially certain consequence of their actions. Ogilvie, as a former employee of Aurelius Media Americas who had been terminated for unauthorized access to Aurelius's content management systems and who had executed a separation agreement explicitly prohibiting the use of Aurelius intellectual property, was fully aware that MDD had no authority to license the Aurelius Works and that StreamNow's exploitation of the Works would constitute infringement.

87. MDD and Ogilvie distributed the Aurelius Works to StreamNow with the object of promoting their use to infringe Plaintiffs' copyrights, within the meaning of Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913 (2005). MDD's entire business model, as applied to the Aurelius Works, was predicated on the unauthorized exploitation of Plaintiffs' copyrighted content through sham licensing arrangements with third-party platforms.

88. Ogilvie's formation of MDD shortly after his termination from Aurelius, in direct violation of his separation agreement, evidences a deliberate and premeditated scheme to exploit Aurelius's intellectual property. Ogilvie leveraged his knowledge of Aurelius's content library, licensing operations, and content management systems — knowledge gained during his employment at AMA — to create a sham intermediary entity through which he could monetize Aurelius's valuable copyrighted Works without authorization.

89. As a direct and proximate result of MDD's and Ogilvie's inducement of copyright infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation.

COUNT IV.

Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 *et seq.*) — Against All Defendants

90. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 89 above as though fully set forth herein.

91. Each Defendant's conduct as alleged herein constitutes unlawful, unfair, and/or fraudulent business acts or practices within the meaning of California Business and Professions Code § 17200 et seq. (the "UCL").

92. StreamNow's unauthorized reproduction, distribution, public performance, and sublicensing of Plaintiffs' copyrighted Works is unlawful because it violates the United States Copyright Act, 17 U.S.C. §§ 106 and 501, and constitutes an unfair business practice that causes substantial injury to Plaintiffs without any countervailing benefit to consumers or competition.

93. MDD's and Ogilvie's unauthorized purported licensing of Plaintiffs' copyrighted content to StreamNow and potentially to other entities, in violation of Ogilvie's separation agreement with Aurelius Media Americas and without any authority from Plaintiffs, is unlawful and unfair. Moreover, MDD's and Ogilvie's false representation to StreamNow that MDD held valid distribution rights to the Aurelius Works constitutes a fraudulent business practice likely to deceive members of the public, including other content distributors and platforms, about MDD's authority and the legitimacy of its content offerings.

94. Defendants have been unjustly enriched as a result of their unfair business practices, having received revenue, profits, and other financial benefits from the unauthorized exploitation of Plaintiffs' copyrighted Works.

95. Plaintiffs are entitled to restitution and injunctive relief under California Business and Professions Code § 17200 et seq.

96. This claim is not preempted by federal copyright law. To the extent Plaintiffs' UCL claim is premised on conduct that constitutes an "extra element" beyond the mere reproduction, distribution, or public performance of copyrighted works — namely, the fraudulent misrepresentation of licensing authority, the systematic scheme to misappropriate Plaintiffs' content through a sham intermediary, the violation of Ogilvie's contractual obligations under his separation agreement, and the deliberate concealment of the unauthorized nature of the distribution — the claim asserts rights that are qualitatively different from the rights protected by the Copyright Act and is therefore not preempted. See Briarpatch Ltd. v. Phoenix Pictures, Inc., 373 F.3d 296, 306 (2d Cir. 2004); Kodadek v. MTV Networks, Inc., 152 F.3d 1209, 1212 (9th Cir. 1998).

COUNT V.

Tortious Interference with Prospective Economic Advantage — Against StreamNow Holdings, Inc.

97. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 96 above as though fully set forth herein.

98. Plaintiffs had existing and prospective economic relationships with authorized streaming platforms, broadcast networks, theatrical exhibitors, and content distributors for the licensing of the 217 Works in the territories where StreamNow made the Works available without authorization. These relationships included active licensing agreements with authorized platforms, pending licensing negotiations with prospective licensees, and established business relationships with content buyers who regularly acquire Aurelius content on commercially reasonable terms.

99. StreamNow knew or should have known of Plaintiffs' existing and prospective licensing relationships. As a sophisticated content platform operator that routinely licenses content from major studios, StreamNow was aware that the Aurelius Works — including globally recognized franchise titles and award-winning properties — were subject to existing and prospective licensing arrangements with authorized distributors. StreamNow's own content acquisition team would have understood that a major international studio such as Aurelius actively licenses its content to competing platforms and distributors.

100. StreamNow's unauthorized distribution of Plaintiffs' copyrighted content at lower price points and through unauthorized channels — including its ad-supported (AVOD) tier and its FAST channel sublicensees, which offered the content for free to end users — constituted an independently wrongful act. Specifically, StreamNow's conduct constituted copyright infringement under 17 U.S.C. §§ 106 and 501, as alleged in Count I above, and unfair business practices under California Business and Professions Code § 17200, as alleged in Count IV above. These independently wrongful acts disrupted Plaintiffs' existing and prospective licensing relationships by undermining the exclusivity and value of Plaintiffs' content offerings to authorized licensees.

101. As a direct and proximate result of StreamNow's tortious interference, Plaintiffs have suffered economic harm in the form of reduced licensing leverage with authorized platforms, lost licensing opportunities with prospective licensees, diminished market value of their content in the affected territories, and injury to their reputation and goodwill as a content licensor.

102. Plaintiffs are entitled to compensatory damages in an amount to be determined at trial.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. respectfully pray that this Court enter judgment in their favor and against Defendants StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie, and grant the following relief:

1. Actual Damages and Infringer's Profits: An award of Plaintiffs' actual damages, including lost licensing revenue of not less than $14.2 million, and Defendant StreamNow's profits attributable to the infringement of not less than $38.6 million, subject to appropriate apportionment to avoid double-counting, for preliminary net recoverable damages estimated at $41.3 million, pursuant to 17 U.S.C. § 504(b);

2. Statutory Damages (In the Alternative): In the alternative to actual damages and profits for the 189 timely-registered Works, an award of statutory damages of up to $150,000 per work for willful infringement pursuant to 17 U.S.C. § 504(c)(2), for a potential aggregate statutory award of up to $28,350,000 for the 189 timely-registered Works, with actual damages and infringer's profits recoverable for the 28 late-registered Works pursuant to 17 U.S.C. § 504(b);

3. Permanent Injunction: A permanent injunction pursuant to 17 U.S.C. § 502 and the Court's inherent equitable authority, enjoining Defendants and each of their officers, directors, agents, servants, employees, successors, assigns, and all persons acting in concert or participation with them, from reproducing, distributing, publicly performing, sublicensing, or otherwise exploiting any of the 217 Works identified in Exhibit A, or any other content owned or controlled by Plaintiffs, in any medium or format, in any territory;

4. Impoundment and Destruction: An order pursuant to 17 U.S.C. § 503 directing the impoundment, during the pendency of this action, of all copies of the Works in Defendants' possession, custody, or control, and upon final judgment, an order directing the destruction or other reasonable disposition of all infringing copies and all masters, molds, matrices, plates, tapes, film negatives, digital files, server images, and all other articles by means of which infringing copies of the Works may be reproduced;

5. Attorneys' Fees and Costs: An award of Plaintiffs' reasonable attorneys' fees and full costs of suit, pursuant to 17 U.S.C. § 505, for the 189 timely-registered Works;

6. Restitution and Injunctive Relief under § 17200: An order of restitution requiring Defendants to disgorge all revenues, profits, and other financial benefits obtained as a result of their unfair business practices, and injunctive relief prohibiting Defendants from engaging in any further unfair, unlawful, or fraudulent business practices with respect to Plaintiffs' content, pursuant to California Business and Professions Code § 17200 et seq.;

7. Compensatory Damages for Tortious Interference: An award of compensatory damages against Defendant StreamNow Holdings, Inc. for its tortious interference with Plaintiffs' prospective economic advantage, in an amount to be determined at trial;

8. Pre-Judgment and Post-Judgment Interest: An award of pre-judgment and post-judgment interest at the maximum rate allowed by law;

9. Such Other and Further Relief: Such other and further relief as this Court deems just, proper, and equitable.

VII. DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiffs hereby demand a trial by jury on all issues and claims so triable in this action.

VIII. SIGNATURE BLOCK

Dated: March __, 2026

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Marcus Delgado (CA Bar No. 247891) Catherine Bloom (CA Bar No. 263504) Wendy Schultz (CA Bar No. 312876) Omar Siddiqui (CA Bar No. 319442)

CALDERWOOD & HARKNESS LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 553-4000 Facsimile: (310) 553-4001

Email: mdelgado@calderwoodharkness.com

Attorneys for Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc.

IX. VERIFICATION

I, Fiona Hartwell, declare as follows:

I am the General Counsel of Aurelius Global Media Group PLC, one of the Plaintiffs in this action. I am authorized to make this verification on behalf of both Plaintiffs, Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. I have reviewed the foregoing Complaint and am familiar with the facts alleged herein. The factual allegations set forth in this Complaint are true and correct to the best of my knowledge, information, and belief, formed after reasonable inquiry. I understand that the information contained in this Complaint may be subject to supplementation and amendment as additional facts are discovered during the course of this litigation.

I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct.

Executed on March __, 2026 London, United Kingdom

________________________________________

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

EXHIBIT A

LIST OF COPYRIGHTED WORKS AT ISSUE

Exhibit A is a separately bound exhibit comprising a complete table of all 217 Works at issue in this action. The table is organized with the following column headers and contains entries for each of the 142 feature films and 75 television series (encompassing 1,038 individual episodes) that are the subject of Plaintiffs' claims. Highlighted franchises include the Meridian franchise (6 films), the Iron Compass series (4 seasons / 48 episodes), and the Thornfield period drama catalog (12 titles). The 189 timely-registered Works and 28 late-registered Works are clearly identified in the Registration Status column.

Table Format:

The full table of 217 entries is attached as a separately bound document and inco

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION
Draft Date: March 10, 2026
Plaintiffs Aurelius Global Media Group PLC ("Aurelius" or "AGMG") and Aurelius Media Americas, Inc. ("AMA" and, together with AGMG, "Plaintiffs"), by and through their undersigned attorneys, Calderwood & Harkness LLP, file this Complaint against Defendants StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie ("Ogilvie" and, together with StreamNow and MDD, "Defendants"), and allege as follows:
I. INTRODUCTION
1. This is an action for copyright infringement under 17 U.S.C. §§ 106 and 501 arising from the unauthorized reproduction, distribution, and public performance of 217 copyrighted audiovisual works (the "Works") owned by Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. This action also asserts claims for contributory copyright infringement, inducement of copyright infringement, unfair business practices under California Business and Professions Code § 17200 et seq., and tortious interference with prospective economic advantage.
2. Defendant StreamNow Holdings, Inc. operated a streaming media "super-aggregator" platform that ingested and exploited Plaintiffs' Works without authorization for a period of approximately twenty-two (22) months, from approximately April 1, 2024 through January 31, 2026. During this period, StreamNow made Plaintiffs' valuable copyrighted content available to its subscribers in fourteen countries, reproduced and stored copies of the Works on its servers and content delivery networks, distributed the Works to end users, publicly performed the Works via streaming, and sublicensed bundles containing the Works to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators — all without any authorization, license, or consent from Plaintiffs.
3. StreamNow purportedly obtained the right to exploit Plaintiffs' content through a sublicense from Defendant Meridian Digital Distributors, LLC, a sham intermediary entity operated by Defendant Franklin Ogilvie. Ogilvie is a former mid-level licensing manager at Aurelius Media Americas, Inc. whose employment was terminated on June 30, 2021 following an internal investigation that revealed unauthorized access to Aurelius's content management systems. Ogilvie had no authority whatsoever to license any Aurelius content, and MDD has never been an authorized distributor of Aurelius. The purported sublicense from MDD to StreamNow is void and of no legal effect as to any Aurelius content.
4. The 217 Works that Defendants exploited without authorization include some of Aurelius's most commercially valuable and culturally significant properties. Among the Works at issue are: (a) the "Meridian" franchise, consisting of six feature films with combined global box office receipts of approximately $1.43 billion; (b) the "Iron Compass" series, Aurelius's highest-rated original dramatic series, encompassing four seasons and forty-eight episodes, averaging 9.2 million viewers per episode in the United Kingdom; and (c) the "Thornfield" period drama catalog, comprising twelve titles and the recipient of seven British Academy of Film and Television Arts ("BAFTA") awards. These properties represent the crown jewels of Aurelius's extensive content library and command premium licensing fees in arm's-length transactions with authorized distributors.
5. StreamNow generated an estimated $38.6 million in revenue directly attributable to the infringing Aurelius content during the twenty-two-month infringement period, comprising subscription revenue, advertising revenue from its ad-supported tier, and sublicensing fees received from FAST channel operators. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a catalog of this size and quality over the relevant time period and in the relevant territories, is estimated at $14.2 million.
6. By this action, Plaintiffs seek actual damages, disgorgement of Defendants' profits attributable to the infringement, statutory damages in the alternative for the 189 timely-registered Works, a permanent injunction prohibiting Defendants from any further exploitation of Plaintiffs' content, impoundment and destruction of all infringing copies, reasonable attorneys' fees and costs, restitution and injunctive relief under California Business and Professions Code § 17200, compensatory damages for tortious interference with prospective economic advantage, and such other and further relief as the Court deems just and proper.
II. THE PARTIES
A. Plaintiffs.
7. Plaintiff Aurelius Global Media Group PLC ("Aurelius" or "AGMG") is a public limited company duly organized and existing under the laws of England and Wales, registered with Companies House under Registration Number 08724561. Aurelius maintains its corporate headquarters at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius's ordinary shares are listed and traded on the Alternative Investment Market ("AIM") of the London Stock Exchange under the ticker symbol "AGLM." In addition, American Depositary Receipts representing Aurelius ordinary shares are traded over-the-counter in the United States.
8. Aurelius is a major international media and entertainment conglomerate with operations spanning content production, acquisition, licensing, distribution, and theatrical exhibition across multiple continents. For the fiscal year ended December 31, 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). Aurelius owns and administers a content library of over 4,200 film and television titles, spanning multiple genres, languages, and decades. The company is led by Chief Executive Officer Sir Alistair Pemberton and General Counsel Fiona Hartwell.
9. Plaintiff Aurelius Media Americas, Inc. ("AMA") is a corporation duly organized and existing under the laws of the State of Delaware. AMA is a wholly-owned subsidiary of Aurelius Global Media Group PLC. AMA maintains its principal place of business at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA manages Aurelius's content licensing, distribution, and intellectual property enforcement operations throughout the United States and the broader Americas region. AMA holds or administers United States copyrights in the Works at issue on behalf of AGMG, including the copyrights in the 217 Works that are the subject of this action.
B. Defendants.
10. Defendant StreamNow Holdings, Inc. ("StreamNow") is a corporation duly organized and existing under the laws of the State of Delaware, Delaware Division of Corporations File Number 7291843. StreamNow maintains its corporate headquarters and principal place of business at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow's registered agent in Delaware is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.
11. StreamNow operates a streaming media "super-aggregator" platform that bundles content from multiple studios, production companies, and independent distributors into a single subscription-based or advertising-supported interface. StreamNow's platform is available to consumers in fourteen countries, including the United States, Canada, Australia, and eleven additional territories. In addition to its direct-to-consumer streaming service, StreamNow sublicenses content bundles to third-party multichannel video programming distributor ("MVPD") operators and FAST channel operators.
12. StreamNow is privately held. Approximately sixty-two percent (62%) of StreamNow's fully diluted equity is owned by Pinnacle Ventures Fund III, LP, a venture capital fund whose general partner is Pinnacle Ventures Management III, LLC (managing partner: Howard Cheng), headquartered at 101 California Street, Suite 3500, San Francisco, California 94111. Pinnacle Ventures Fund III, LP invested $145 million in StreamNow's Series C financing round, which closed in June 2022. StreamNow's estimated revenue for the fiscal year ended December 31, 2025 was approximately $312 million.
13. StreamNow's senior leadership includes Chief Executive Officer and Co-Founder Derek Calloway, Chief Operating Officer and Co-Founder Priya Menon, General Counsel Tobias Rennert, and Vice President of Content Acquisition Sandra Yee. On information and belief, StreamNow's outside litigation counsel is the firm of Grantham Roth & Pearce LLP, located at 555 South Flower Street, Suite 4200, Los Angeles, California 90071 (lead partner: Victoria Langford; associate: Brian Matsuda).
14. Defendant Meridian Digital Distributors, LLC ("MDD") is a limited liability company organized and existing under the laws of the State of California, California Secretary of State File Number 202115729430. MDD's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211. MDD was formed in late 2021 by Defendant Franklin Ogilvie. Ogilvie is MDD's sole member and manager. As of February 2026, MDD's status with the California Secretary of State is listed as "Active." MDD purported to license Aurelius content to StreamNow but had no authority, license, or right of any kind to do so.
15. Defendant Franklin Ogilvie ("Ogilvie") is an individual residing in or around Los Angeles, California. Ogilvie is the sole member and manager of Meridian Digital Distributors, LLC. Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. Ogilvie's employment was terminated following an internal investigation that revealed unauthorized access to Aurelius's proprietary content management systems. Upon his termination, Ogilvie executed a separation agreement dated June 30, 2021, which contained, among other provisions: (i) a non-compete clause; (ii) a non-solicitation clause; and (iii) an explicit prohibition on the use of any Aurelius intellectual property. Ogilvie formed MDD in late 2021, shortly after his departure from Aurelius, and thereafter used MDD as a vehicle to exploit Aurelius's copyrighted content without authorization.
III. JURISDICTION AND VENUE
A. Subject Matter Jurisdiction
16. This Court has original subject matter jurisdiction over Plaintiffs' federal copyright infringement claims (Counts I, II, and III) pursuant to 28 U.S.C. § 1331 (federal question jurisdiction) and 28 U.S.C. § 1338(a) (jurisdiction over actions arising under the Copyright Act).
17. This Court has supplemental jurisdiction over Plaintiffs' state law claims (Counts IV and V) pursuant to 28 U.S.C. § 1367(a), because those claims are so related to the federal copyright claims within the original jurisdiction of this Court that they form part of the same case or controversy under Article III of the United States Constitution. Specifically, Plaintiffs' state law claims for unfair business practices and tortious interference with prospective economic advantage arise from the same nucleus of operative facts as the federal copyright infringement claims — namely, Defendants' unauthorized exploitation of Plaintiffs' copyrighted Works through the sham MDD sublicensing arrangement.
B. Personal Jurisdiction
18. This Court has personal jurisdiction over Defendant StreamNow Holdings, Inc. because StreamNow is headquartered in and maintains its principal place of business in Los Angeles, California, which is within the Central District of California. StreamNow conducts continuous and systematic business operations within this District and within the State of California.
19. This Court has personal jurisdiction over Defendant Meridian Digital Distributors, LLC because MDD is a California limited liability company with its registered address in Beverly Hills, California, which is within the Central District of California. MDD was organized under the laws of the State of California and, on information and belief, conducts business within this District and within the State of California.
20. This Court has personal jurisdiction over Defendant Franklin Ogilvie because Ogilvie resides in or around Los Angeles, California, which is within the Central District of California. Ogilvie conducted the acts giving rise to this action, including the formation of MDD, the negotiation and execution of the purported Content Distribution Agreement with StreamNow, and the delivery of infringing content to StreamNow, within the Central District of California and within the State of California.
21. Each Defendant has sufficient minimum contacts with the State of California and with this District such that the exercise of personal jurisdiction over each Defendant comports with due process and is consistent with the requirements of the California long-arm statute, Cal. Code Civ. Proc. § 410.10.
C. Venue.
22. Venue is proper in this District under 28 U.S.C. § 1400(a), which provides that civil actions arising under the copyright laws may be instituted in the district in which the defendant or the defendant's agent resides or may be found. All Defendants reside in, are domiciled in, or have their principal places of business within the Central District of California.
23. Venue is also proper under 28 U.S.C. § 1391(b)(1) and (b)(2), as all Defendants reside in this judicial district, and a substantial part of the events or omissions giving rise to the claims asserted herein occurred within this District. Specifically, the negotiation and execution of the purported Content Distribution Agreement between MDD and StreamNow, the ingestion and streaming of the infringing content on StreamNow's platform, and the sublicensing of the infringing content to FAST channel operators all occurred in whole or in substantial part within the Central District of California.
IV. FACTUAL ALLEGATIONS
A. Aurelius and Its Copyrighted Works
24. Aurelius Global Media Group PLC is a leading international media and entertainment conglomerate headquartered in London, United Kingdom. With a storied history spanning multiple decades, Aurelius has built one of the most valuable and diverse content libraries in the entertainment industry, comprising over 4,200 film and television titles. The library includes globally recognized franchises, critically acclaimed dramatic works, award-winning documentaries, and commercially successful genre films, spanning a wide range of creative expression.
25. Among the most commercially valuable and culturally significant properties in the Aurelius library are the following, each of which is at issue in this action:
(a) The "Meridian" Franchise: A series of six interconnected feature films in the science fiction and action-adventure genres, produced between 2011 and 2023, with combined worldwide theatrical box office receipts of approximately $1.43 billion. The Meridian franchise is one of the highest-grossing original film franchises in Aurelius's history and commands premium licensing fees across all distribution windows.
(b) The "Iron Compass" Series: Aurelius's highest-rated original dramatic television series, comprising four seasons and forty-eight individual episodes. The series, a critically acclaimed espionage thriller set during the Cold War, averaged 9.2 million viewers per episode in the United Kingdom during its initial broadcast run and has been widely licensed to international broadcasters and streaming platforms. The series has received numerous industry awards and nominations and remains a cornerstone of Aurelius's television content strategy.
(c) The "Thornfield" Period Drama Catalog: A collection of twelve distinguished period drama titles — encompassing feature films and limited television series — produced over a span of approximately fifteen years. The Thornfield catalog has been the recipient of seven BAFTA awards and has garnered international acclaim for its production values, performances, and historical authenticity. The catalog is a prestige property that anchors Aurelius's licensing negotiations with premium content buyers worldwide.
26. Aurelius, through its wholly-owned subsidiary Aurelius Media Americas, Inc., owns all right, title, and interest in and to the copyrights in the 217 audiovisual Works at issue in this action (collectively, the "Works"). The 217 Works comprise 142 feature films and 75 television series encompassing a total of 1,038 individual episodes.
27. Aurelius licenses its content to authorized streaming platforms, broadcast networks, theatrical exhibitors, and content distributors worldwide through carefully negotiated licensing agreements. These agreements are managed by Aurelius's Senior Vice President of Content Licensing and Distribution, Raj Anantharam, and its Head of Digital Rights Enforcement, Lena Kowalski, in coordination with AMA's licensing team. Aurelius employs a sophisticated windowing and territorial licensing strategy designed to maximize the value of its content across distribution platforms, geographic markets, and release windows. The unauthorized availability of Aurelius content on unlicensed platforms directly undermines this strategy and causes substantial economic harm to Aurelius's licensing program.
B. Copyright Registrations
28. Of the 217 Works at issue in this action, 189 Works have valid and timely United States copyright registrations. These 189 registrations were obtained within three months of the date of first publication of each respective Work, or prior to the commencement of Defendants' infringement, thereby satisfying the registration timing requirements for eligibility for statutory damages and attorneys' fees under 17 U.S.C. §§ 412, 504(c), and 505.
29. The remaining 28 Works have valid United States copyright registrations that post-date the commencement of Defendants' infringement. These 28 registrations were obtained between May 2024 and October 2025. Although these registrations satisfy the jurisdictional prerequisite for suit under 17 U.S.C. § 411(a), the Works covered by these registrations are eligible only for an award of actual damages and infringer's profits under 17 U.S.C. § 504(b), and not for statutory damages or attorneys' fees.
30. All 217 copyright registrations were verified by Lexington IP Services, Inc. (Marissa Chung, Director of Copyright Research) through a comprehensive search of the records maintained by the United States Copyright Office. That search was completed on January 22, 2026 and confirmed the validity and currency of each registration.
31. A complete list of the 217 Works, together with their respective titles, types (feature film or television series), number of episodes (for television series), United States Copyright Registration numbers, registration dates, dates of first publication, registration status (timely or late), and registrant entity, is attached hereto as Exhibit A and incorporated herein by reference.
C. Franklin Ogilvie and Meridian Digital Distributors, LLC
32. Defendant Franklin Ogilvie was employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately 2017 through June 30, 2021. In that capacity, Ogilvie was responsible for assisting with the administration of content licensing agreements in the Americas region and had access to Aurelius's proprietary content management systems, including databases of title metadata, licensing terms, and distribution schedules.
33. Ogilvie's employment at Aurelius Media Americas was terminated effective June 30, 2021 following an internal investigation conducted by AMA's Human Resources and Legal departments. The investigation revealed that Ogilvie had engaged in unauthorized access to Aurelius's content management systems, including accessing files, databases, and systems beyond the scope of his authorized role and responsibilities.
34. On June 30, 2021, in connection with the termination of his employment, Ogilvie executed a separation agreement with Aurelius Media Americas, Inc. The separation agreement contained, among other material provisions: (i) a non-compete clause prohibiting Ogilvie from engaging in competitive activities with Aurelius for a specified period following the termination of his employment; (ii) a non-solicitation clause prohibiting Ogilvie from soliciting Aurelius's clients, customers, or business partners; and (iii) an explicit prohibition on the use, reproduction, distribution, or exploitation of any Aurelius intellectual property, including copyrighted content, trade secrets, proprietary data, and confidential business information.
35. In late 2021, approximately five months after his departure from Aurelius, Ogilvie formed Meridian Digital Distributors, LLC as a California limited liability company (California Secretary of State File Number 202115729430). Ogilvie registered himself as the sole member and manager of MDD. The entity's registered address is 8912 Burton Way, Suite 200, Beverly Hills, California 90211.
36. Aurelius has never granted MDD any license, sublicense, distribution agreement, letter of authorization, or any other form of permission or authority to reproduce, distribute, publicly perform, sublicense, or otherwise exploit any Aurelius-owned content. MDD has never been an authorized distributor of Aurelius. No officer, director, employee, or agent of Aurelius or AMA has ever authorized MDD or Ogilvie to act on Aurelius's behalf in connection with any content licensing or distribution transaction.
37. Despite the foregoing, Ogilvie, acting through MDD, falsely represented to StreamNow — and, on information and belief, potentially to other entities — that MDD held valid distribution rights to Aurelius content. These representations were materially false and were made in violation of Ogilvie's separation agreement and in furtherance of a deliberate scheme to misappropriate and exploit Aurelius's valuable copyrighted Works for Ogilvie's personal financial benefit.
D. The MDD–StreamNow Content Distribution Agreement
38. On or about March 15, 2024, Meridian Digital Distributors, LLC and StreamNow Holdings, Inc. executed a purported "Content Distribution Agreement" (the "MDD–StreamNow Agreement"). On information and belief, the MDD–StreamNow Agreement purported to grant StreamNow certain rights to reproduce, distribute, and publicly perform a catalog of more than 350 titles, including the 217 Aurelius Works at issue in this action.
39. Sandra Yee, StreamNow's Vice President of Content Acquisition, acknowledged in an email communication dated November 3, 2025 — sent in response to an inquiry from Raj Anantharam, Aurelius's Senior Vice President of Content Licensing and Distribution — that StreamNow obtained the Aurelius content through a sublicense from MDD. Yee's email stated, in substance, that StreamNow's rights to the Aurelius titles were derived from the Content Distribution Agreement with MDD and that StreamNow understood MDD to be an authorized distributor of the content.
40. MDD had no authority to grant StreamNow or any other party any rights in the Aurelius Works. The MDD–StreamNow Agreement is therefore void and of no legal effect as to any Aurelius content. MDD could not convey rights that it did not possess, and StreamNow acquired no valid rights to the Aurelius Works through the MDD–StreamNow Agreement.
41. StreamNow failed to conduct reasonable due diligence regarding MDD's purported authority to license the Aurelius Works. Had StreamNow undertaken even minimal due diligence — such as contacting Aurelius or AMA directly, reviewing publicly available information about MDD's sole member and his prior employment at Aurelius, or verifying the chain of title for a catalog of 217 titles from a major international studio — StreamNow would have discovered that MDD had no authority to license Aurelius content. The fact that MDD's sole member and manager, Franklin Ogilvie, was a recently terminated employee of Aurelius Media Americas, Inc. was a readily ascertainable fact and should have served as a significant red flag warranting heightened scrutiny of MDD's claimed licensing authority. StreamNow's failure to conduct such due diligence was, at a minimum, reckless and reflects a deliberate indifference to the rights of content owners.
E. StreamNow's Unauthorized Exploitation of the Works
42. Beginning on or about April 1, 2024, StreamNow ingested the 217 Aurelius Works into its platform content library. The ingestion process involved receiving digital master files of the Works from MDD, encoding or transcoding the files into formats suitable for streaming delivery, and uploading the files to StreamNow's servers and content delivery networks.
43. From approximately April 1, 2024 through at least January 31, 2026 — a period of approximately twenty-two (22) months — StreamNow made the 217 Works available for streaming to its subscribers in the United States, Canada, Australia, and eleven additional international territories, for a total of fourteen countries.
44. StreamNow reproduced the Works within the meaning of 17 U.S.C. § 106(1) by making and storing multiple copies of the Works on its servers, content delivery networks, and associated storage infrastructure. Each reproduction was made without authorization from Plaintiffs.
45. StreamNow distributed the Works within the meaning of 17 U.S.C. § 106(3) by transmitting copies of the Works to end users via its streaming platform. Each such transmission constituted a distribution of the Works to the public without authorization from Plaintiffs.
46. StreamNow publicly performed the Works within the meaning of 17 U.S.C. § 106(4) by streaming the Works to its subscribers. Each streaming transmission constituted a public performance of the Works without authorization from Plaintiffs.
47. The unauthorized exploitation continued unabated for the full twenty-two-month period, during which time StreamNow's subscriber base accessed the Aurelius Works through both StreamNow's subscription tier and its ad-supported (AVOD) tier. StreamNow featured a number of the Aurelius titles prominently in its platform interface, including in curated recommendation carousels, editorial playlists, and algorithmic recommendations, thereby actively directing subscriber attention to the infringing content.
48. StreamNow is not a passive hosting service or mere conduit for content. StreamNow exercises editorial control over its content catalog, including the selection of titles for inclusion on its platform, the curation and organization of content within its user interface, the establishment of pricing tiers and subscription models, and the determination of geographic availability for individual titles. StreamNow actively negotiates licensing agreements (or purports to negotiate licensing agreements) with content suppliers, sets the terms under which content is made available to consumers, and directly monetizes the content through subscription fees, advertising revenue, and sublicensing arrangements.
F. StreamNow's Sublicensing to FAST Channel Operators
49. In addition to exploiting the Aurelius Works through its own direct-to-consumer streaming platform, StreamNow sublicensed content bundles containing Aurelius titles to at least four third-party Free Ad-Supported Streaming Television ("FAST") channel operators. On information and belief, these sublicensing arrangements were made pursuant to StreamNow's standard FAST channel distribution agreements, under which StreamNow grants FAST channel operators the right to stream bundled content catalogs on their ad-supported channels in exchange for sublicensing fees and/or revenue-sharing arrangements.
50. The four FAST channel operators to which StreamNow sublicensed bundles containing Aurelius content are:
(a) Brindoval Channel Networks, Inc., a company based in Dallas, Texas;
(b) BrightLoop Media, LLC, a company based in Miami, Florida;
(c) Velvet Stream Partners, LP, a company based in Toronto, Ontario, Canada; and
(d) Pacific Lantern Digital Pty Ltd, a company based in Sydney, New South Wales, Australia.
51. Each of these FAST channel operators further reproduced, distributed, and publicly performed the Aurelius Works without Aurelius's authorization, extending the reach of the unauthorized exploitation beyond StreamNow's own platform to additional consumer-facing distribution channels. Aurelius never authorized StreamNow to sublicense its content to any third party, and StreamNow had no right to grant any sublicenses in Aurelius content because it had no valid license itself.
G. Revenue Attribution and Damages
52. Plaintiffs retained CipherTrace Analytics, LLC ("CipherTrace"), a digital forensic analytics firm, to identify and quantify StreamNow's revenue attributable to the infringing Aurelius content. Dr. Nathan Frey served as the engagement lead for CipherTrace's analysis. CipherTrace's analysis drew upon publicly available data, industry benchmarking data, and preliminary information obtained through Plaintiffs' pre-filing investigation, and yielded the following revenue attributions:
(a) Subscription Revenue: Subscription revenue allocable to the Aurelius titles was estimated at $22.4 million, based on CipherTrace's refined viewership share model with premium-tier weighting. This model allocates subscription revenue among individual titles based on their proportionate share of total viewership hours, adjusted to reflect the premium value of high-profile franchise titles (such as the Meridian franchise and Iron Compass series) that disproportionately drive subscriber acquisition and retention.
(b) Advertising Revenue (AVOD Tier): Advertising revenue allocable to the Aurelius titles was estimated at $9.7 million, based on ad impression data associated with the viewing of Aurelius content on StreamNow's ad-supported tier.
(c) Sublicensing Fees: Sublicensing fees received by StreamNow from FAST channel operators for content bundles containing Aurelius titles were estimated at $6.5 million, based on StreamNow's reported sublicensing revenue and the proportionate share of Aurelius titles within the sublicensed bundles.
(d) Total Attributable Revenue: The total revenue attributable to StreamNow's unauthorized exploitation of the Aurelius Works was estimated at $38.6 million.
53. Plaintiffs' lost licensing revenue, based on the fair market value of comparable arm's-length licenses for a catalog of similar size, quality, and market appeal over a period of twenty-two months in the relevant territories, is estimated at $14.2 million. This estimate is based on Aurelius's existing licensing agreements with authorized platforms for comparable content catalogs, adjusted for the specific titles, territories, and time period at issue.
54. Plaintiffs also retained Hargrove Economic Consulting Group, LLC ("Hargrove"), to prepare a preliminary damages analysis. Dr. Elena Vasquez of Hargrove served as the lead consultant. Dr. Vasquez's analysis estimates net recoverable damages of $41.3 million, comprising Plaintiffs' actual damages (lost licensing revenue) plus StreamNow's infringer's profits, with appropriate apportionment to avoid double-counting in accordance with 17 U.S.C. § 504(b). Plaintiffs reserve the right to supplement and revise this damages analysis as additional information becomes available through discovery.
55. In the alternative, for the 189 Works with timely copyright registrations, Plaintiffs are entitled to elect statutory damages in lieu of actual damages and profits. Under 17 U.S.C. § 504(c)(2), where infringement is committed willfully, the Court may award statutory damages of up to $150,000 per work infringed. For the 189 timely-registered Works, the potential aggregate statutory damages award is up to $28,350,000 (189 × $150,000). For the remaining 28 late-registered Works, Plaintiffs' recovery is limited to actual damages and infringer's profits. Plaintiffs note that the combined total across all 217 Works, assuming willful infringement, yields a potential statutory component of up to $28,350,000 for the 189 timely-registered Works, supplemented by actual damages for the remaining 28 Works.
H. Discovery of the Infringement
56. On October 15, 2025, Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, discovered that numerous Aurelius titles were streaming on the StreamNow platform without authorization. Kowalski identified the presence of Aurelius-owned content during a routine content monitoring sweep of digital streaming platforms conducted as part of Aurelius's ongoing intellectual property enforcement program.
57. On October 22, 2025, Kowalski escalated the matter to Fiona Hartwell, General Counsel of Aurelius Global Media Group PLC. Upon receiving Kowalski's report, Hartwell authorized the commencement of a formal internal investigation to determine the scope and source of the unauthorized distribution.
58. On November 3, 2025, Sandra Yee, StreamNow's Vice President of Content Acquisition, responded to an informal inquiry from Raj Anantharam, Aurelius's Senior Vice President of Content Licensing and Distribution, regarding the source of StreamNow's purported rights to the Aurelius content. In her response, Yee stated that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC and indicated that StreamNow considered MDD to be an authorized distributor of the content.
59. On November 18, 2025, Aurelius engaged Bexley Marsh Solicitors LLP, a London-based law firm, to conduct a preliminary legal assessment of the matter, including an evaluation of the jurisdictional and substantive legal issues implicated by the unauthorized distribution.
60. On December 5, 2025, Bexley Marsh Solicitors LLP completed its preliminary assessment and recommended that Aurelius engage United States counsel to pursue the copyright infringement claims arising under U.S. law in a U.S. federal court.
61. On January 8, 2026, Aurelius and AMA contacted Calderwood & Harkness LLP regarding potential representation in connection with the unauthorized exploitation of the Aurelius Works.
62. On January 15, 2026, Marcus Delgado, Partner at Calderwood & Harkness LLP, and Fiona Hartwell, General Counsel of Aurelius, held an initial consultation to discuss the facts, legal theories, and potential claims.
63. On February 12, 2026, Calderwood & Harkness LLP formally opened the engagement under Matter Number 1017-00003 and commenced preparation of this Complaint.
I. DMCA Safe Harbor Does Not Apply
64. StreamNow does not qualify for protection under the safe harbor provisions of Section 512 of the Digital Millennium Copyright Act ("DMCA"), 17 U.S.C. § 512.
65. The DMCA safe harbors, including the safe harbor for hosting services under 17 U.S.C. § 512(c) and the safe harbor for information location tools under 17 U.S.C. § 512(d), are available only to "service providers" that function as passive intermediaries in the transmission, storage, or location of user-generated or user-uploaded content. These safe harbors do not extend to entities that actively acquire, curate, license, and monetize copyrighted content as a core element of their business model.
66. StreamNow is not a passive hosting service, internet service provider, or mere intermediary. StreamNow actively curates its content catalog, affirmatively negotiating licenses (or purporting to negotiate licenses) with content suppliers and selectively choosing which titles to include in its platform library. StreamNow exercises editorial control over the selection, organization, and presentation of content on its platform, including the placement of titles in curated recommendation carousels, editorial playlists, and genre categories. StreamNow sets pricing tiers for its subscription and ad-supported services, controls the geographic availability of individual titles across its fourteen-country footprint, and directly monetizes the content through subscription fees, advertising revenue, and sublicensing fees charged to FAST channel operators.
67. StreamNow's active, affirmative, and central role in the acquisition, curation, promotion, and monetization of the infringing content places it squarely outside the scope of the DMCA safe harbor provisions. StreamNow is not entitled to any limitation of liability under Section 512 of the DMCA.
J. StreamNow's Infringement Was Willful
68. StreamNow's infringement of Plaintiffs' copyrights was willful within the meaning of 17 U.S.C. § 504(c)(2). The following facts, individually and collectively, demonstrate the willful nature of StreamNow's infringement:
(a) Sophisticated Operator: StreamNow is a sophisticated content platform operator with substantial experience in the content licensing industry. StreamNow routinely negotiates and executes licensing agreements with major studios, production companies, and independent distributors. StreamNow maintains a dedicated content acquisition department led by a Vice President of Content Acquisition and employs a General Counsel responsible for overseeing the company's legal compliance. StreamNow is therefore well aware of the importance of verifying the chain of title and licensing authority of its content suppliers.
(b) Failure to Conduct Due Diligence: Despite its sophistication and experience, StreamNow failed to conduct reasonable due diligence regarding MDD's authority to license the Aurelius Works. StreamNow did not contact Aurelius or AMA to verify MDD's claimed distribution rights. StreamNow did not request or obtain any documentation establishing MDD's chain of title to the Aurelius content. StreamNow did not investigate the provenance of a catalog of 217 titles from a major international studio that was being offered by a small, recently formed intermediary with no track record in the industry.
(c) Readily Available Red Flags: Franklin Ogilvie's prior employment at Aurelius Media Americas, Inc. and the circumstances of his departure were matters of readily ascertainable public record and industry knowledge. A basic internet search, a review of MDD's corporate filings, or a simple inquiry to Aurelius would have revealed that MDD's sole principal was a former Aurelius employee whose employment had been recently terminated. These facts constituted obvious red flags that should have prompted heightened scrutiny of MDD's claimed licensing authority.
(d) Massive Scale of Infringement: The scale of StreamNow's infringement was massive, encompassing 217 individual titles, including globally recognized franchises and award-winning properties from a major international media conglomerate. The sheer volume and value of the content involved made it implausible that a small, unknown intermediary like MDD would hold legitimate distribution rights to such a catalog.
(e) Prolonged Duration: StreamNow continued to exploit the Aurelius Works for approximately twenty-two months, from April 2024 through January 2026, without ever verifying MDD's authority or contacting Aurelius regarding the source of the content.
(f) Continued Exploitation After Notice: StreamNow continued to exploit the Aurelius Works even after Aurelius raised concerns and inquired about the source of StreamNow's claimed rights. Following the November 3, 2025 email exchange between Sandra Yee and Raj Anantharam, StreamNow did not remove the Aurelius content from its platform or take any steps to investigate MDD's authority. Instead, StreamNow continued to stream the Works and, on information and belief, continued to receive sublicensing revenue from FAST channel operators for bundles containing the Works.
(g) Sublicensing to Third Parties: StreamNow further compounded its infringement by sublicensing the Aurelius content to at least four FAST channel operators, thereby expanding the unauthorized distribution of Plaintiffs' Works to additional platforms and audiences beyond StreamNow's own subscriber base. This sublicensing activity demonstrates StreamNow's aggressive and deliberate exploitation of the infringing content for maximum commercial gain.
K. Impact on Aurelius's Licensing Program
69. StreamNow's unauthorized availability of Aurelius content on its platform and through its FAST channel sublicensees has demonstrably reduced Aurelius's licensing leverage with authorized platforms and distributors. When unauthorized copies of premium content are available to consumers through competing distribution channels at lower price points or through free, ad-supported tiers, the willingness of authorized licensees to pay fair market rates for exclusive or semi-exclusive rights to that content is materially diminished.
70. The unauthorized exploitation has undermined Aurelius's carefully managed windowing and territorial licensing strategies. Aurelius structures its content licensing program to maximize revenue by controlling the timing, geographic scope, and platform exclusivity of content releases. StreamNow's unauthorized distribution of the Works across fourteen countries, without regard for Aurelius's existing territorial licensing commitments or windowing schedules, has created market confusion and eroded the value of Aurelius's content in multiple territories.
71. As a result of Defendants' conduct, Aurelius has suffered harm to its goodwill and reputation as a content licensor. Aurelius's authorized distribution partners and prospective licensees have a reasonable expectation that Aurelius will protect the exclusivity and value of the content it licenses. The unauthorized availability of Aurelius content on StreamNow and through its FAST channel sublicensees undermines confidence in Aurelius's ability to control its own distribution pipeline and protect the rights of its authorized partners.
V. CLAIMS FOR RELIEF
COUNT I.
Copyright Infringement (17 U.S.C. §§ 106, 501) — Against StreamNow Holdings, Inc.
72. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 71 above as though fully set forth herein.
73. Plaintiffs are the owners of valid copyrights in the 217 Works, as evidenced by the United States Copyright Office registrations identified in Exhibit A attached hereto. Plaintiffs' copyright registrations satisfy the registration requirement for bringing an action for infringement under 17 U.S.C. § 411(a).
74. StreamNow, without authorization, license, or consent from Plaintiffs, has reproduced the 217 Works by making and storing copies on its servers and content delivery networks, in violation of Plaintiffs' exclusive right of reproduction under 17 U.S.C. § 106(1).
75. StreamNow, without authorization, license, or consent from Plaintiffs, has distributed the 217 Works by transmitting copies to end users via its streaming platform, in violation of Plaintiffs' exclusive right of distribution under 17 U.S.C. § 106(3).
76. StreamNow, without authorization, license, or consent from Plaintiffs, has publicly performed the 217 Works by streaming the Works to its subscribers and, through its sublicensing arrangements, to the subscribers of FAST channel operators, in violation of Plaintiffs' exclusive right of public performance under 17 U.S.C. § 106(4).
77. StreamNow's infringement of Plaintiffs' copyrights was willful, as set forth in detail in Paragraphs 68(a) through 68(g) above. StreamNow acted with knowledge of Plaintiffs' copyrights, or with reckless disregard or willful blindness to Plaintiffs' rights, in reproducing, distributing, and publicly performing the Works without obtaining authorization from Plaintiffs or conducting reasonable due diligence regarding the source of MDD's purported licensing authority.
78. As a direct and proximate result of StreamNow's infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation. Plaintiffs are entitled to recover their actual damages and StreamNow's profits attributable to the infringement, pursuant to 17 U.S.C. § 504(b), or, in the alternative, statutory damages for the 189 timely-registered Works, pursuant to 17 U.S.C. § 504(c).
COUNT II.
Contributory Copyright Infringement — Against Meridian Digital Distributors, LLC and Franklin Ogilvie
79. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 78 above as though fully set forth herein.
80. MDD and Ogilvie, with actual knowledge that they had no authority, license, or right to license the Aurelius Works, provided the Works to StreamNow and materially contributed to StreamNow's direct infringement of Plaintiffs' copyrights. Specifically, MDD and Ogilvie supplied the digital master files or access credentials for the 217 Works to StreamNow, entered into the purported Content Distribution Agreement that served as the vehicle for StreamNow's acquisition and exploitation of the Works, and falsely represented to StreamNow that MDD held valid distribution rights to the Works.
81. MDD and Ogilvie knew, or had reason to know, that their purported licensing of the Aurelius Works to StreamNow would result in the unauthorized reproduction, distribution, and public performance of the Works by StreamNow — conduct that constitutes direct copyright infringement, as alleged in Count I above.
82. MDD and Ogilvie induced, caused, and materially contributed to StreamNow's infringing activity by providing the infringing content, facilitating StreamNow's access to and exploitation of the content, and creating the false pretense of licensing authority that enabled StreamNow to ingest and stream the Works on its platform.
83. As a direct and proximate result of MDD's and Ogilvie's contributory infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation.
COUNT III.
Inducement of Copyright Infringement — Against Meridian Digital Distributors, LLC and Franklin Ogilvie
84. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 83 above as though fully set forth herein.
85. MDD and Ogilvie actively induced StreamNow's infringement of Plaintiffs' copyrights by affirmatively representing to StreamNow that MDD held valid distribution rights to the Aurelius Works and by entering into the Content Distribution Agreement dated on or about March 15, 2024, pursuant to which MDD purported to grant StreamNow the right to reproduce, distribute, and publicly perform the Aurelius Works.
86. MDD and Ogilvie acted with the specific intent to cause StreamNow to infringe Plaintiffs' copyrights, or, at a minimum, with actual knowledge that copyright infringement would be a foreseeable and substantially certain consequence of their actions. Ogilvie, as a former employee of Aurelius Media Americas who had been terminated for unauthorized access to Aurelius's content management systems and who had executed a separation agreement explicitly prohibiting the use of Aurelius intellectual property, was fully aware that MDD had no authority to license the Aurelius Works and that StreamNow's exploitation of the Works would constitute infringement.
87. MDD and Ogilvie distributed the Aurelius Works to StreamNow with the object of promoting their use to infringe Plaintiffs' copyrights, within the meaning of Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913 (2005). MDD's entire business model, as applied to the Aurelius Works, was predicated on the unauthorized exploitation of Plaintiffs' copyrighted content through sham licensing arrangements with third-party platforms.
88. Ogilvie's formation of MDD shortly after his termination from Aurelius, in direct violation of his separation agreement, evidences a deliberate and premeditated scheme to exploit Aurelius's intellectual property. Ogilvie leveraged his knowledge of Aurelius's content library, licensing operations, and content management systems — knowledge gained during his employment at AMA — to create a sham intermediary entity through which he could monetize Aurelius's valuable copyrighted Works without authorization.
89. As a direct and proximate result of MDD's and Ogilvie's inducement of copyright infringement, Plaintiffs have suffered and continue to suffer damages, including but not limited to lost licensing revenue, diminution in the market value of their content, and injury to their licensing program, goodwill, and business reputation.
COUNT IV.
Unfair Business Practices (Cal. Bus. & Prof. Code § 17200 *et seq.*) — Against All Defendants
90. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 89 above as though fully set forth herein.
91. Each Defendant's conduct as alleged herein constitutes unlawful, unfair, and/or fraudulent business acts or practices within the meaning of California Business and Professions Code § 17200 et seq. (the "UCL").
92. StreamNow's unauthorized reproduction, distribution, public performance, and sublicensing of Plaintiffs' copyrighted Works is unlawful because it violates the United States Copyright Act, 17 U.S.C. §§ 106 and 501, and constitutes an unfair business practice that causes substantial injury to Plaintiffs without any countervailing benefit to consumers or competition.
93. MDD's and Ogilvie's unauthorized purported licensing of Plaintiffs' copyrighted content to StreamNow and potentially to other entities, in violation of Ogilvie's separation agreement with Aurelius Media Americas and without any authority from Plaintiffs, is unlawful and unfair. Moreover, MDD's and Ogilvie's false representation to StreamNow that MDD held valid distribution rights to the Aurelius Works constitutes a fraudulent business practice likely to deceive members of the public, including other content distributors and platforms, about MDD's authority and the legitimacy of its content offerings.
94. Defendants have been unjustly enriched as a result of their unfair business practices, having received revenue, profits, and other financial benefits from the unauthorized exploitation of Plaintiffs' copyrighted Works.
95. Plaintiffs are entitled to restitution and injunctive relief under California Business and Professions Code § 17200 et seq.
96. This claim is not preempted by federal copyright law. To the extent Plaintiffs' UCL claim is premised on conduct that constitutes an "extra element" beyond the mere reproduction, distribution, or public performance of copyrighted works — namely, the fraudulent misrepresentation of licensing authority, the systematic scheme to misappropriate Plaintiffs' content through a sham intermediary, the violation of Ogilvie's contractual obligations under his separation agreement, and the deliberate concealment of the unauthorized nature of the distribution — the claim asserts rights that are qualitatively different from the rights protected by the Copyright Act and is therefore not preempted. See Briarpatch Ltd. v. Phoenix Pictures, Inc., 373 F.3d 296, 306 (2d Cir. 2004); Kodadek v. MTV Networks, Inc., 152 F.3d 1209, 1212 (9th Cir. 1998).
COUNT V.
Tortious Interference with Prospective Economic Advantage — Against StreamNow Holdings, Inc.
97. Plaintiffs incorporate by reference each and every allegation set forth in Paragraphs 1 through 96 above as though fully set forth herein.
98. Plaintiffs had existing and prospective economic relationships with authorized streaming platforms, broadcast networks, theatrical exhibitors, and content distributors for the licensing of the 217 Works in the territories where StreamNow made the Works available without authorization. These relationships included active licensing agreements with authorized platforms, pending licensing negotiations with prospective licensees, and established business relationships with content buyers who regularly acquire Aurelius content on commercially reasonable terms.
99. StreamNow knew or should have known of Plaintiffs' existing and prospective licensing relationships. As a sophisticated content platform operator that routinely licenses content from major studios, StreamNow was aware that the Aurelius Works — including globally recognized franchise titles and award-winning properties — were subject to existing and prospective licensing arrangements with authorized distributors. StreamNow's own content acquisition team would have understood that a major international studio such as Aurelius actively licenses its content to competing platforms and distributors.
100. StreamNow's unauthorized distribution of Plaintiffs' copyrighted content at lower price points and through unauthorized channels — including its ad-supported (AVOD) tier and its FAST channel sublicensees, which offered the content for free to end users — constituted an independently wrongful act. Specifically, StreamNow's conduct constituted copyright infringement under 17 U.S.C. §§ 106 and 501, as alleged in Count I above, and unfair business practices under California Business and Professions Code § 17200, as alleged in Count IV above. These independently wrongful acts disrupted Plaintiffs' existing and prospective licensing relationships by undermining the exclusivity and value of Plaintiffs' content offerings to authorized licensees.
101. As a direct and proximate result of StreamNow's tortious interference, Plaintiffs have suffered economic harm in the form of reduced licensing leverage with authorized platforms, lost licensing opportunities with prospective licensees, diminished market value of their content in the affected territories, and injury to their reputation and goodwill as a content licensor.
102. Plaintiffs are entitled to compensatory damages in an amount to be determined at trial.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. respectfully pray that this Court enter judgment in their favor and against Defendants StreamNow Holdings, Inc., Meridian Digital Distributors, LLC, and Franklin Ogilvie, and grant the following relief:
1. Actual Damages and Infringer's Profits: An award of Plaintiffs' actual damages, including lost licensing revenue of not less than $14.2 million, and Defendant StreamNow's profits attributable to the infringement of not less than $38.6 million, subject to appropriate apportionment to avoid double-counting, for preliminary net recoverable damages estimated at $41.3 million, pursuant to 17 U.S.C. § 504(b);
2. Statutory Damages (In the Alternative): In the alternative to actual damages and profits for the 189 timely-registered Works, an award of statutory damages of up to $150,000 per work for willful infringement pursuant to 17 U.S.C. § 504(c)(2), for a potential aggregate statutory award of up to $28,350,000 for the 189 timely-registered Works, with actual damages and infringer's profits recoverable for the 28 late-registered Works pursuant to 17 U.S.C. § 504(b);
3. Permanent Injunction: A permanent injunction pursuant to 17 U.S.C. § 502 and the Court's inherent equitable authority, enjoining Defendants and each of their officers, directors, agents, servants, employees, successors, assigns, and all persons acting in concert or participation with them, from reproducing, distributing, publicly performing, sublicensing, or otherwise exploiting any of the 217 Works identified in Exhibit A, or any other content owned or controlled by Plaintiffs, in any medium or format, in any territory;
4. Impoundment and Destruction: An order pursuant to 17 U.S.C. § 503 directing the impoundment, during the pendency of this action, of all copies of the Works in Defendants' possession, custody, or control, and upon final judgment, an order directing the destruction or other reasonable disposition of all infringing copies and all masters, molds, matrices, plates, tapes, film negatives, digital files, server images, and all other articles by means of which infringing copies of the Works may be reproduced;
5. Attorneys' Fees and Costs: An award of Plaintiffs' reasonable attorneys' fees and full costs of suit, pursuant to 17 U.S.C. § 505, for the 189 timely-registered Works;
6. Restitution and Injunctive Relief under § 17200: An order of restitution requiring Defendants to disgorge all revenues, profits, and other financial benefits obtained as a result of their unfair business practices, and injunctive relief prohibiting Defendants from engaging in any further unfair, unlawful, or fraudulent business practices with respect to Plaintiffs' content, pursuant to California Business and Professions Code § 17200 et seq.;
7. Compensatory Damages for Tortious Interference: An award of compensatory damages against Defendant StreamNow Holdings, Inc. for its tortious interference with Plaintiffs' prospective economic advantage, in an amount to be determined at trial;
8. Pre-Judgment and Post-Judgment Interest: An award of pre-judgment and post-judgment interest at the maximum rate allowed by law;
9. Such Other and Further Relief: Such other and further relief as this Court deems just, proper, and equitable.
VII. DEMAND FOR JURY TRIAL
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiffs hereby demand a trial by jury on all issues and claims so triable in this action.
VIII. SIGNATURE BLOCK
Dated: March __, 2026
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Marcus Delgado (CA Bar No. 247891) Catherine Bloom (CA Bar No. 263504) Wendy Schultz (CA Bar No. 312876) Omar Siddiqui (CA Bar No. 319442)
CALDERWOOD & HARKNESS LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 553-4000 Facsimile: (310) 553-4001
Email: mdelgado@calderwoodharkness.com
Attorneys for Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc.
IX. VERIFICATION
I, Fiona Hartwell, declare as follows:
I am the General Counsel of Aurelius Global Media Group PLC, one of the Plaintiffs in this action. I am authorized to make this verification on behalf of both Plaintiffs, Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. I have reviewed the foregoing Complaint and am familiar with the facts alleged herein. The factual allegations set forth in this Complaint are true and correct to the best of my knowledge, information, and belief, formed after reasonable inquiry. I understand that the information contained in this Complaint may be subject to supplementation and amendment as additional facts are discovered during the course of this litigation.
I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct.
Executed on March __, 2026 London, United Kingdom
________________________________________
Fiona Hartwell General Counsel Aurelius Global Media Group PLC 45 Clarewood Place London W1K 6TH, United Kingdom
EXHIBIT A
LIST OF COPYRIGHTED WORKS AT ISSUE
Exhibit A is a separately bound exhibit comprising a complete table of all 217 Works at issue in this action. The table is organized with the following column headers and contains entries for each of the 142 feature films and 75 television series (encompassing 1,038 individual episodes) that are the subject of Plaintiffs' claims. Highlighted franchises include the Meridian franchise (6 films), the Iron Compass series (4 seasons / 48 episodes), and the Thornfield period drama catalog (12 titles). The 189 timely-registered Works and 28 late-registered Works are clearly identified in the Registration Status column.
Table Format:
The full table of 217 entries is attached as a separately bound document and inco