1017-00003 · Aurelius Global Media Group · Litigation Readiness

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION

DECLARATION OF LENA KOWALSKI

I, Lena Kowalski, hereby declare as follows under penalty of perjury pursuant to 28 U.S.C. § 1746. The facts set forth in this declaration are based on my personal knowledge, my review of business records maintained in the ordinary course of business by Aurelius Global Media Group PLC and its subsidiaries, and information obtained during the internal investigation that I supervised and directed. Where any statement herein is based on information and belief rather than direct personal knowledge, I have identified the basis for that belief. I am competent to testify to the matters stated herein, and if called as a witness, I could and would testify competently to the following:

1. My full name is Lena Kowalski. I am the Head of Digital Rights Enforcement at Aurelius Global Media Group PLC ("Aurelius" or "AGMG"). Aurelius is a public limited company incorporated in England and Wales under the Companies Act 2006, registered with Companies House under Registration Number 08724561, and headquartered at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Exchange's AIM market under the ticker symbol AGLM, and its American Depositary Receipts ("ADRs") are traded on the over-the-counter market in the United States. For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at an exchange rate of £1.00 = $1.26), making it one of the largest independent media companies headquartered in the United Kingdom.

2. In my role as Head of Digital Rights Enforcement, I am responsible for monitoring, detecting, and enforcing Aurelius's digital rights across all platforms and territories worldwide. I report directly to Fiona Hartwell, General Counsel of Aurelius. In addition, I work closely with Raj Anantharam, Senior Vice President of Content Licensing & Distribution, who oversees all of Aurelius's authorized content licensing arrangements with third-party platforms and distributors. I oversee a dedicated team of fourteen professionals focused on digital rights monitoring, anti-piracy operations, and platform compliance across all territories in which Aurelius content is distributed. I have held this position since January 2019. Prior to joining Aurelius, I spent approximately eight years in digital content protection and copyright enforcement roles at other major media and entertainment companies. I have extensive experience in detecting, investigating, and remediating unauthorized distribution of copyrighted audiovisual content across digital platforms.

3. Aurelius owns and controls a library of over 4,200 film and television titles. Content in Aurelius's library is produced and acquired through Aurelius and its wholly-owned subsidiaries, including Aurelius Media Americas, Inc. ("AMA"), a corporation organized under the laws of the State of Delaware, with principal offices located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as Aurelius's primary operational entity for content production, licensing, and distribution activities in the United States and throughout the Western Hemisphere. Aurelius's library includes a number of high-value, commercially significant franchises and catalogs, including, among others:

(a) The "Meridian" franchise, which comprises six feature films released between 2012 and 2024, with a combined global box office of approximately $1.43 billion. The Meridian franchise is one of Aurelius's most valuable intellectual properties and a cornerstone of the company's content licensing strategy;

(b) The "Iron Compass" series, an original dramatic television series produced by Aurelius that has run for four seasons totaling forty-eight episodes. Iron Compass is Aurelius's highest-rated original series, averaging approximately 9.2 million viewers per episode in the United Kingdom during its initial broadcast windows, and has been licensed to premium streaming platforms in over thirty territories worldwide; and

(c) The "Thornfield" period drama catalog, which comprises twelve titles spanning feature films and limited series. The Thornfield catalog has won seven British Academy of Film and Television Arts ("BAFTA") awards and is widely regarded as a hallmark of premium British dramatic content.

Content licensing is a core revenue stream for Aurelius. Aurelius carefully controls the licensing of its content to authorized platforms through individually negotiated agreements that reflect the specific value, territory, term, and exclusivity requirements applicable to each title and each licensee relationship.

4. This declaration concerns 217 specific audiovisual works owned by Aurelius that are at issue in this action (the "Works at Issue" or the "217 Works"). The 217 Works comprise 142 feature films and 75 television series, the latter totaling 1,038 individual episodes. The Works at Issue include titles from across Aurelius's library, including all six films in the Meridian franchise, all four seasons (forty-eight episodes) of the Iron Compass series, and all twelve titles in the Thornfield catalog, among numerous other commercially valuable works. All 217 Works are registered with the United States Copyright Office. Of these, 189 titles have timely registrations — that is, they were registered with the Copyright Office either within three months of first publication or prior to the commencement of the infringing conduct at issue in this action. The remaining twenty-eight titles were registered between May 2024 and October 2025. The copyright registration details for all 217 Works have been independently verified by Lexington IP Services, Inc., a copyright research firm engaged by counsel, Calderwood & Harkness LLP. Lexington IP Services completed its comprehensive search and verification of the registration records on January 22, 2026, and its findings are consistent with Aurelius's internal records. A complete list of the 217 Works, cross-referenced to their respective U.S. Copyright Office registration numbers, is set forth in Exhibit B attached hereto.

5. On October 15, 2025, in the course of routine digital rights monitoring activities that I conduct and supervise on an ongoing basis, I personally discovered that a substantial number of Aurelius-owned film and television titles were available for streaming on the platform operated by StreamNow Holdings, Inc. ("StreamNow"). StreamNow is a corporation organized under the laws of the State of Delaware (Delaware Division of Corporations File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a "super-aggregator" streaming platform — a service that bundles content from multiple sources, including content owners, distributors, and sublicensors, into a single subscription-based or advertising-supported ("AVOD") interface available to consumers. According to StreamNow's own public disclosures and marketing materials, the StreamNow platform is available to users in fourteen countries, including the United States, Canada, Australia, the United Kingdom, Germany, France, Spain, Italy, the Netherlands, Sweden, Brazil, Mexico, Japan, and South Korea.

On October 15, 2025, I was able to access and confirm the presence of Aurelius titles on StreamNow's platform through its public-facing interface, including title pages, promotional artwork, and metadata associated with the Works at Issue. I also accessed the StreamNow platform through a subscriber account established by my team for monitoring purposes and confirmed that the Aurelius titles were available for full-length streaming by paying subscribers and, in certain cases, by users of StreamNow's free, ad-supported tier. To my knowledge and based on the records available to me — including Aurelius's comprehensive licensing database, content management systems, and correspondence records — Aurelius has never entered into any license, sublicense, or distribution agreement with StreamNow authorizing the use, reproduction, distribution, or public performance of any Aurelius content on StreamNow's platform or through any StreamNow-operated service. The discovery was alarming given the breadth and commercial significance of the titles involved, which represent a substantial portion of Aurelius's most valuable intellectual property.

6. On October 22, 2025, I escalated the matter to Fiona Hartwell, General Counsel of Aurelius, providing Ms. Hartwell with a detailed written memorandum summarizing my findings, including the number of titles identified, representative screenshots and metadata captures, and a preliminary assessment of the scope and duration of the unauthorized distribution. At Ms. Hartwell's direction, I commenced a formal internal investigation to determine the full scope and nature of the unauthorized use of Aurelius content on StreamNow's platform and to identify the source of StreamNow's purported authorization to distribute Aurelius's Works. The investigation involved a comprehensive review of Aurelius's licensing databases, content management systems, and correspondence records to confirm that no authorization had been granted — directly or indirectly — for StreamNow or any intermediary entity to distribute the affected titles. The investigation also involved close coordination with Raj Anantharam, Senior Vice President of Content Licensing & Distribution, who is responsible for all authorized content licensing arrangements entered into by Aurelius and its subsidiaries. Mr. Anantharam and his licensing team assisted in cross-referencing the 217 titles identified on StreamNow's platform against Aurelius's records of active, expired, and terminated licensing agreements.

7. Based on my thorough review of Aurelius's licensing records and content management systems, and after consultation with Mr. Anantharam and members of his licensing team, I can confirm the following:

(a) Aurelius has never executed any license agreement, sublicense agreement, distribution agreement, or any other form of authorization with StreamNow Holdings, Inc. with respect to any Aurelius-owned content, including but not limited to the 217 Works at Issue in this action.

(b) Aurelius has never authorized StreamNow to reproduce, distribute, publicly perform, display, or otherwise exploit any Aurelius-owned content in any medium, format, or territory.

(c) Aurelius has never executed any license agreement, sublicense agreement, distribution agreement, or any other form of authorization with Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with a registered address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

(d) MDD is not and has never been an authorized distributor, agent, licensee, or sublicensee of Aurelius content. MDD does not appear in Aurelius's licensing database in any capacity, and no representative of MDD has ever been in contact with Aurelius's licensing team through any authorized channel.

(e) Aurelius has never authorized any intermediary, agent, distributor, or other third party to sublicense, distribute, or otherwise convey rights in Aurelius content to StreamNow or to MDD.

In short, neither StreamNow nor MDD had or has any lawful authority whatsoever to reproduce, distribute, or publicly perform any of the 217 Aurelius Works at Issue.

8. In connection with the internal investigation, Mr. Anantharam, at my request and with the approval of General Counsel, made an informal inquiry to StreamNow regarding the source of the Aurelius content appearing on its platform. On November 3, 2025, Sandra Yee, Vice President of Content Acquisition at StreamNow, responded to Mr. Anantharam via email. In her email, Ms. Yee claimed that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC. Specifically, Ms. Yee's email referenced a "Content Distribution Agreement" between MDD and StreamNow that was allegedly executed on or about March 15, 2024, and that purportedly covered more than 350 titles, including the 217 Aurelius titles at issue in this action. Ms. Yee's email stated, in relevant part, that StreamNow understood MDD to be an authorized distributor of Aurelius's content and that StreamNow had relied on MDD's representations in entering into the Content Distribution Agreement and in making the Aurelius titles available on its platform. As stated above, and as I have confirmed through exhaustive review of Aurelius's records, Aurelius has never granted MDD any rights to any Aurelius content. MDD's purported authority to license or sublicense Aurelius content is entirely fictitious and unauthorized. A true and correct copy of the November 3, 2025 email from Sandra Yee is attached hereto as Exhibit C.

9. The sole member and manager of Meridian Digital Distributors, LLC is Franklin Ogilvie. Mr. Ogilvie was formerly employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately June 2017 to June 30, 2021. During his employment, Mr. Ogilvie was involved in various aspects of Aurelius's content licensing operations, including the preparation of license agreements, management of content delivery workflows, and interaction with Aurelius's content management systems. Mr. Ogilvie's employment with AMA was terminated on June 30, 2021, following an internal investigation into unauthorized access to Aurelius's content management systems and associated records. The details of the internal investigation that led to Mr. Ogilvie's termination are documented in AMA's human resources files and are known to me based on my review of those records in connection with the present investigation. Upon his departure, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, a non-compete clause, a non-solicitation clause, and an explicit prohibition on the use of any Aurelius intellectual property, trade secrets, confidential information, or proprietary materials following the termination of his employment.

Based on publicly available records maintained by the California Secretary of State, MDD was incorporated in late 2021 — approximately four to five months after Mr. Ogilvie's departure from Aurelius. I believe, based on the foregoing facts, that Mr. Ogilvie used knowledge, information, and familiarity with Aurelius's content library, licensing practices, and content management systems gained during his employment at Aurelius to falsely represent to StreamNow and potentially to other third parties that MDD had authority to license and distribute Aurelius content. The timing of MDD's formation, Mr. Ogilvie's prior role at Aurelius, and MDD's purported representation that it was authorized to distribute Aurelius content collectively support this belief.

10. The unauthorized availability of the 217 Aurelius titles on StreamNow's platform has been ongoing for approximately twenty-two months, from approximately April 1, 2024, through at least January 31, 2026, based on the analysis conducted by my team and confirmed through the forensic investigation performed by CipherTrace Analytics, LLC. During this entire period, the titles were made available for streaming to subscribers and, in many cases, to ad-supported users in the United States, Canada, Australia, and eleven additional territories — a total of fourteen countries. In addition to making the Aurelius content available directly on its own platform, StreamNow sublicensed bundles of content containing Aurelius titles to at least four third-party free ad-supported streaming television ("FAST") channel operators, thereby further expanding the unauthorized distribution of Aurelius's Works. The four downstream sublicensees identified to date are:

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

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

(3) Velvet Stream Partners, LP, an entity based in Toronto, Ontario, Canada; and

(4) Pacific Lantern Digital Pty Ltd, an entity based in Sydney, New South Wales, Australia.

Through StreamNow and these downstream sublicensees, Aurelius's copyrighted content has been made widely available to the public across multiple platforms and territories without any compensation to Aurelius and without Aurelius's knowledge or consent. The downstream sublicensing amplified the unauthorized distribution far beyond StreamNow's own platform, exponentially increasing the harm to Aurelius.

11. Based on my understanding of the analysis conducted by CipherTrace Analytics, LLC, the digital forensics and analytics firm retained by counsel in connection with this matter, StreamNow generated an estimated $38.6 million in total revenue attributable to the 217 Aurelius titles during the approximately twenty-two-month infringement period. This estimated total revenue comprises the following components:

(a) Subscription revenue: Approximately $22.4 million, based on a refined viewership share analysis with premium-tier weighting that attributes a proportional share of StreamNow's subscription revenue to viewership of Aurelius titles relative to total platform viewership;

(b) Advertising revenue (AVOD tier): Approximately $9.7 million, derived from advertising impressions and revenue generated by streams of Aurelius titles on StreamNow's free, ad-supported tier; and

(c) Sublicensing fees: Approximately $6.5 million, representing fees received by StreamNow from the four FAST channel operators identified in Paragraph 10 above for content bundles containing Aurelius titles.

None of this revenue — not a single dollar — has been shared with or paid to Aurelius. Aurelius has received zero compensation for the use of its content on StreamNow's platform or on any of the downstream sublicensee platforms. The full methodology and analysis underlying these revenue estimates are addressed in the separate declaration of Dr. Nathan Frey of CipherTrace Analytics, LLC, which is being filed concurrently with this declaration in support of Plaintiff's motion.

12. The unauthorized availability of Aurelius content on StreamNow's platform and the four FAST channel sublicensees has caused and continues to cause irreparable harm to Aurelius's licensing program in several significant and compounding ways:

(a) Erosion of Licensing Value. Aurelius licenses its content to authorized streaming platforms and distributors through carefully negotiated, arm's-length agreements that reflect the specific commercial value of each title, the territory, the term, the exclusivity provisions, and other material terms. The fair market value of a comparable license for the 217 Works at Issue over a twenty-two-month period in the relevant territories is estimated at approximately $14.2 million, based on Aurelius's historical licensing rates and comparable transactions. StreamNow's unauthorized availability of the same content — at lower cost or no additional cost to consumers on StreamNow's platform — directly undermines Aurelius's ability to command fair market rates from authorized licensees. Prospective and existing licensees have less incentive to pay premium rates for content that is already available elsewhere on an unauthorized basis. This erosion of licensing value is ongoing and worsens with each day that the unauthorized availability continues.

(b) Loss of Exclusivity. Many of Aurelius's licensing agreements with authorized platforms include exclusivity provisions that guarantee the licensee sole access to specified Aurelius titles within defined territories and time windows. The unauthorized presence of Aurelius titles on StreamNow's platform and on the platforms of StreamNow's four downstream sublicensees directly jeopardizes Aurelius's existing exclusive license arrangements. Aurelius faces a real and substantial risk that authorized partners who have paid for exclusive rights will assert breach-of-exclusivity claims against Aurelius, seek price reductions or renegotiations of existing agreements, or decline to renew or enter into new agreements. This risk is not speculative — I am aware that at least one authorized licensing partner has already raised concerns informally about the availability of certain Aurelius titles on platforms other than those covered by the partner's exclusive license.

(c) Competitive Harm and Market Displacement. StreamNow's unauthorized offering competes directly with Aurelius's authorized distribution channels and with the platforms of Aurelius's authorized licensees. Consumers who access Aurelius content on StreamNow or on the downstream FAST channels are diverted from platforms where Aurelius receives proper compensation. This competitive displacement reduces the value of Aurelius's content to authorized partners and diminishes Aurelius's ability to generate revenue from its own content in the marketplace.

(d) Diminution of Content Value. Each day that the 217 Works at Issue remain available on unauthorized platforms, the perceived market value and freshness of the content diminishes. This is particularly harmful for tentpole franchises such as Meridian, Iron Compass, and Thornfield, where the timing and exclusivity of availability windows are critical to maximizing the commercial value of new and catalog releases. Unauthorized early or concurrent availability on competing platforms reduces consumer demand on authorized platforms and undermines the carefully orchestrated release and windowing strategies that Aurelius employs to maximize the long-term value of its content library.

13. Beyond the direct economic harms to Aurelius's licensing program, the unauthorized distribution of Aurelius content on StreamNow's platform and through the downstream sublicensees has caused and continues to cause significant reputational harm to Aurelius. Aurelius's reputation as a premium content provider — both among consumers and within the media and entertainment industry — depends on its ability to control the quality, presentation, and distribution of its works. Aurelius invests substantial resources in ensuring that its content is presented to audiences with high-quality encoding, appropriate metadata, accurate subtitles and closed captions, and a user experience that reflects the premium nature of the Aurelius brand.

StreamNow's unauthorized use raises serious and well-founded concerns about the quality of encoding, presentation, and user experience associated with Aurelius content on an unauthorized platform — matters over which Aurelius has no control and no ability to monitor or remediate. The unauthorized distribution also creates confusion among consumers and industry partners about the authorized sources of Aurelius content, damaging Aurelius's brand integrity and its relationships with authorized licensees and distribution partners who expect Aurelius to maintain strict control over where and how its content appears.

14. As of the date of this declaration, I have confirmed through continued monitoring by my team that Aurelius titles remain available on StreamNow's platform. The infringement is ongoing and continues to cause harm to Aurelius with each passing day. Each additional day of unauthorized availability results in further viewership of Aurelius content on unauthorized channels, further displacement of viewership from authorized platforms, further erosion of licensing value, and further reputational harm. Without immediate injunctive relief from this Court, Aurelius will continue to suffer irreparable harm that cannot be adequately compensated by monetary damages alone, because:

(a) The loss of licensing leverage and exclusivity value is difficult to quantify with precision, as it depends on the future behavior of existing and prospective licensing partners and on market conditions that are inherently uncertain;

(b) The competitive displacement of authorized partners is ongoing and compounding, and the resulting harm to Aurelius's commercial relationships cannot be fully captured in a damages calculation;

(c) The reputational harm and brand dilution caused by unauthorized distribution on platforms outside Aurelius's control cannot be reversed or adequately remedied by a post-trial monetary judgment; and

(d) New viewers continue to access Aurelius content through unauthorized channels every day, further depleting the available market for authorized distribution and diminishing the commercial value of future licensing opportunities.

15. While Aurelius intends to pursue the full measure of its actual damages, statutory damages where applicable, and the disgorgement of StreamNow's profits attributable to the unauthorized exploitation of Aurelius content, monetary damages alone are insufficient to compensate Aurelius for the ongoing and compounding harms described above. The harm to Aurelius's licensing relationships, exclusivity commitments, brand reputation, and future content value is inherently irreparable in nature. No amount of money awarded at the conclusion of this litigation can restore the licensing leverage that Aurelius has lost, repair the relationships with authorized partners that have been strained, undo the consumer confusion that has been created, or recover the diminished market value of content that has been widely available on unauthorized platforms for nearly two years. Only immediate injunctive relief — requiring StreamNow to cease all reproduction, distribution, public performance, and other exploitation of the 217 Aurelius Works at Issue and to remove all Aurelius content from its platform and from all sublicensed channels — can prevent further irreparable injury to Aurelius.

16. Aurelius invests significant resources in monitoring and enforcing its digital rights worldwide, and I oversee the dedicated team responsible for detecting unauthorized distribution of Aurelius content across digital platforms, websites, and services. Upon discovery of the StreamNow infringement, Aurelius acted promptly and diligently to investigate the matter and to pursue its legal rights. The following timeline reflects the key steps taken by Aurelius following the initial discovery:

• October 15, 2025: My team and I discovered the unauthorized presence of Aurelius titles on StreamNow's platform during routine digital rights monitoring activities.

• October 22, 2025: I escalated the matter to Fiona Hartwell, General Counsel of Aurelius, and a formal internal investigation was commenced under my supervision.

• November 3, 2025: Sandra Yee, VP of Content Acquisition at StreamNow, responded to Mr. Anantharam's inquiry, claiming that StreamNow had obtained the Aurelius content through a sublicense from MDD.

• November 18, 2025: Aurelius engaged Bexley Marsh Solicitors LLP, London, for a preliminary legal assessment under English law, given the potential cross-border implications of the infringement.

• December 5, 2025: Bexley Marsh recommended that Aurelius engage experienced United States litigation counsel to pursue enforcement of Aurelius's rights under U.S. copyright law, given that StreamNow is a U.S. entity, the infringing platform is operated from the United States, and the primary distribution occurs in U.S. territory.

• January 8, 2026: Aurelius contacted Calderwood & Harkness LLP in Los Angeles regarding potential representation.

• January 15, 2026: An initial consultation took place between Marcus Delgado, Partner at Calderwood & Harkness LLP, and Fiona Hartwell, General Counsel of Aurelius.

• February 12, 2026: Calderwood & Harkness LLP's engagement was formally opened under Matter Number 1017-00003, and the firm commenced its pre-filing investigation and preparation of this action.

• March 14, 2026 (target): Service of formal cease-and-desist and demand letter on StreamNow Holdings, Inc., concurrent with or immediately following the filing of this action and the instant motion for emergency injunctive relief.

Aurelius has pursued its rights diligently and without unreasonable delay at every stage following the initial discovery. The period between discovery and the filing of this action reflects the time necessarily required to conduct a thorough internal investigation, retain and consult with qualified counsel on both sides of the Atlantic, verify copyright registrations, engage forensic analysts, and prepare the comprehensive record necessary to support this motion.

17. The following exhibits are attached to or referenced in this declaration in support of the factual assertions set forth herein:

• Exhibit A: Representative screenshots of Aurelius titles appearing on StreamNow's platform, including title pages, promotional artwork, and metadata, captured during monitoring activities conducted by my team between October 15, 2025, and February 28, 2026.

• Exhibit B: Complete list of the 217 Works at Issue, including title, format (feature film or television series), number of episodes (for television series), and corresponding U.S. Copyright Office registration number(s), cross-referenced to the Copyright Registration Summary Report prepared by Lexington IP Services, Inc.

• Exhibit C: True and correct copy of the email from Sandra Yee, Vice President of Content Acquisition, StreamNow Holdings, Inc., to Raj Anantharam, Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC, dated November 3, 2025.

• Exhibit D: Summary excerpts from Aurelius's licensing database confirming that no license, sublicense, distribution agreement, or other authorization has been granted to StreamNow Holdings, Inc. or to Meridian Digital Distributors, LLC with respect to any Aurelius content.

The full forensic analysis of StreamNow's revenue attributable to the unauthorized exploitation of Aurelius content, including the methodology, data sources, and conclusions of CipherTrace Analytics, LLC, is addressed in the separate declaration of Dr. Nathan Frey, Managing Director of CipherTrace Analytics, LLC, which is being filed concurrently with this declaration in support of Plaintiff's motion.

ATTESTATION

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

Executed on ____, 2026, at Los Angeles, California.

________________________________________

Lena Kowalski Head of Digital Rights Enforcement Aurelius Global Media Group PLC 45 Clarewood Place, London W1K 6TH, United Kingdom c/o Aurelius Media Americas, Inc. 1900 Avenue of the Stars, Suite 2200 Los Angeles, California 90067

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

Email: osiddiqui@calderwoodharkness.com

Reviewed by: Wendy Schultz, Senior Associate Marcus Delgado, Partner

Matter No.: 1017-00003

DRAFT — Subject to revision prior to filing

AURELIUS GLOBAL MEDIA GROUP PLC, a public limited company organized under the laws of England and Wales,	Case No.: [To be assigned upon filing]
Plaintiff,	DECLARATION OF LENA KOWALSKI IN SUPPORT OF PLAINTIFF'S MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION

STREAMNOW HOLDINGS, INC., a Delaware corporation; MERIDIAN DIGITAL DISTRIBUTORS, LLC, a California limited liability company; and FRANKLIN OGILVIE, an individual,

Defendants.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION
DECLARATION OF LENA KOWALSKI
I, Lena Kowalski, hereby declare as follows under penalty of perjury pursuant to 28 U.S.C. § 1746. The facts set forth in this declaration are based on my personal knowledge, my review of business records maintained in the ordinary course of business by Aurelius Global Media Group PLC and its subsidiaries, and information obtained during the internal investigation that I supervised and directed. Where any statement herein is based on information and belief rather than direct personal knowledge, I have identified the basis for that belief. I am competent to testify to the matters stated herein, and if called as a witness, I could and would testify competently to the following:
1. My full name is Lena Kowalski. I am the Head of Digital Rights Enforcement at Aurelius Global Media Group PLC ("Aurelius" or "AGMG"). Aurelius is a public limited company incorporated in England and Wales under the Companies Act 2006, registered with Companies House under Registration Number 08724561, and headquartered at 45 Clarewood Place, London W1K 6TH, United Kingdom. Aurelius is listed on the London Stock Exchange's AIM market under the ticker symbol AGLM, and its American Depositary Receipts ("ADRs") are traded on the over-the-counter market in the United States. For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at an exchange rate of £1.00 = $1.26), making it one of the largest independent media companies headquartered in the United Kingdom.
2. In my role as Head of Digital Rights Enforcement, I am responsible for monitoring, detecting, and enforcing Aurelius's digital rights across all platforms and territories worldwide. I report directly to Fiona Hartwell, General Counsel of Aurelius. In addition, I work closely with Raj Anantharam, Senior Vice President of Content Licensing & Distribution, who oversees all of Aurelius's authorized content licensing arrangements with third-party platforms and distributors. I oversee a dedicated team of fourteen professionals focused on digital rights monitoring, anti-piracy operations, and platform compliance across all territories in which Aurelius content is distributed. I have held this position since January 2019. Prior to joining Aurelius, I spent approximately eight years in digital content protection and copyright enforcement roles at other major media and entertainment companies. I have extensive experience in detecting, investigating, and remediating unauthorized distribution of copyrighted audiovisual content across digital platforms.
3. Aurelius owns and controls a library of over 4,200 film and television titles. Content in Aurelius's library is produced and acquired through Aurelius and its wholly-owned subsidiaries, including Aurelius Media Americas, Inc. ("AMA"), a corporation organized under the laws of the State of Delaware, with principal offices located at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as Aurelius's primary operational entity for content production, licensing, and distribution activities in the United States and throughout the Western Hemisphere. Aurelius's library includes a number of high-value, commercially significant franchises and catalogs, including, among others:
(a) The "Meridian" franchise, which comprises six feature films released between 2012 and 2024, with a combined global box office of approximately $1.43 billion. The Meridian franchise is one of Aurelius's most valuable intellectual properties and a cornerstone of the company's content licensing strategy;
(b) The "Iron Compass" series, an original dramatic television series produced by Aurelius that has run for four seasons totaling forty-eight episodes. Iron Compass is Aurelius's highest-rated original series, averaging approximately 9.2 million viewers per episode in the United Kingdom during its initial broadcast windows, and has been licensed to premium streaming platforms in over thirty territories worldwide; and
(c) The "Thornfield" period drama catalog, which comprises twelve titles spanning feature films and limited series. The Thornfield catalog has won seven British Academy of Film and Television Arts ("BAFTA") awards and is widely regarded as a hallmark of premium British dramatic content.
Content licensing is a core revenue stream for Aurelius. Aurelius carefully controls the licensing of its content to authorized platforms through individually negotiated agreements that reflect the specific value, territory, term, and exclusivity requirements applicable to each title and each licensee relationship.
4. This declaration concerns 217 specific audiovisual works owned by Aurelius that are at issue in this action (the "Works at Issue" or the "217 Works"). The 217 Works comprise 142 feature films and 75 television series, the latter totaling 1,038 individual episodes. The Works at Issue include titles from across Aurelius's library, including all six films in the Meridian franchise, all four seasons (forty-eight episodes) of the Iron Compass series, and all twelve titles in the Thornfield catalog, among numerous other commercially valuable works. All 217 Works are registered with the United States Copyright Office. Of these, 189 titles have timely registrations — that is, they were registered with the Copyright Office either within three months of first publication or prior to the commencement of the infringing conduct at issue in this action. The remaining twenty-eight titles were registered between May 2024 and October 2025. The copyright registration details for all 217 Works have been independently verified by Lexington IP Services, Inc., a copyright research firm engaged by counsel, Calderwood & Harkness LLP. Lexington IP Services completed its comprehensive search and verification of the registration records on January 22, 2026, and its findings are consistent with Aurelius's internal records. A complete list of the 217 Works, cross-referenced to their respective U.S. Copyright Office registration numbers, is set forth in Exhibit B attached hereto.
5. On October 15, 2025, in the course of routine digital rights monitoring activities that I conduct and supervise on an ongoing basis, I personally discovered that a substantial number of Aurelius-owned film and television titles were available for streaming on the platform operated by StreamNow Holdings, Inc. ("StreamNow"). StreamNow is a corporation organized under the laws of the State of Delaware (Delaware Division of Corporations File No. 7291843), headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow operates a "super-aggregator" streaming platform — a service that bundles content from multiple sources, including content owners, distributors, and sublicensors, into a single subscription-based or advertising-supported ("AVOD") interface available to consumers. According to StreamNow's own public disclosures and marketing materials, the StreamNow platform is available to users in fourteen countries, including the United States, Canada, Australia, the United Kingdom, Germany, France, Spain, Italy, the Netherlands, Sweden, Brazil, Mexico, Japan, and South Korea.
On October 15, 2025, I was able to access and confirm the presence of Aurelius titles on StreamNow's platform through its public-facing interface, including title pages, promotional artwork, and metadata associated with the Works at Issue. I also accessed the StreamNow platform through a subscriber account established by my team for monitoring purposes and confirmed that the Aurelius titles were available for full-length streaming by paying subscribers and, in certain cases, by users of StreamNow's free, ad-supported tier. To my knowledge and based on the records available to me — including Aurelius's comprehensive licensing database, content management systems, and correspondence records — Aurelius has never entered into any license, sublicense, or distribution agreement with StreamNow authorizing the use, reproduction, distribution, or public performance of any Aurelius content on StreamNow's platform or through any StreamNow-operated service. The discovery was alarming given the breadth and commercial significance of the titles involved, which represent a substantial portion of Aurelius's most valuable intellectual property.
6. On October 22, 2025, I escalated the matter to Fiona Hartwell, General Counsel of Aurelius, providing Ms. Hartwell with a detailed written memorandum summarizing my findings, including the number of titles identified, representative screenshots and metadata captures, and a preliminary assessment of the scope and duration of the unauthorized distribution. At Ms. Hartwell's direction, I commenced a formal internal investigation to determine the full scope and nature of the unauthorized use of Aurelius content on StreamNow's platform and to identify the source of StreamNow's purported authorization to distribute Aurelius's Works. The investigation involved a comprehensive review of Aurelius's licensing databases, content management systems, and correspondence records to confirm that no authorization had been granted — directly or indirectly — for StreamNow or any intermediary entity to distribute the affected titles. The investigation also involved close coordination with Raj Anantharam, Senior Vice President of Content Licensing & Distribution, who is responsible for all authorized content licensing arrangements entered into by Aurelius and its subsidiaries. Mr. Anantharam and his licensing team assisted in cross-referencing the 217 titles identified on StreamNow's platform against Aurelius's records of active, expired, and terminated licensing agreements.
7. Based on my thorough review of Aurelius's licensing records and content management systems, and after consultation with Mr. Anantharam and members of his licensing team, I can confirm the following:
(a) Aurelius has never executed any license agreement, sublicense agreement, distribution agreement, or any other form of authorization with StreamNow Holdings, Inc. with respect to any Aurelius-owned content, including but not limited to the 217 Works at Issue in this action.
(b) Aurelius has never authorized StreamNow to reproduce, distribute, publicly perform, display, or otherwise exploit any Aurelius-owned content in any medium, format, or territory.
(c) Aurelius has never executed any license agreement, sublicense agreement, distribution agreement, or any other form of authorization with Meridian Digital Distributors, LLC ("MDD"), a California limited liability company (California Secretary of State File No. 202115729430) with a registered address at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.
(d) MDD is not and has never been an authorized distributor, agent, licensee, or sublicensee of Aurelius content. MDD does not appear in Aurelius's licensing database in any capacity, and no representative of MDD has ever been in contact with Aurelius's licensing team through any authorized channel.
(e) Aurelius has never authorized any intermediary, agent, distributor, or other third party to sublicense, distribute, or otherwise convey rights in Aurelius content to StreamNow or to MDD.
In short, neither StreamNow nor MDD had or has any lawful authority whatsoever to reproduce, distribute, or publicly perform any of the 217 Aurelius Works at Issue.
8. In connection with the internal investigation, Mr. Anantharam, at my request and with the approval of General Counsel, made an informal inquiry to StreamNow regarding the source of the Aurelius content appearing on its platform. On November 3, 2025, Sandra Yee, Vice President of Content Acquisition at StreamNow, responded to Mr. Anantharam via email. In her email, Ms. Yee claimed that StreamNow had obtained the Aurelius content through a sublicense from Meridian Digital Distributors, LLC. Specifically, Ms. Yee's email referenced a "Content Distribution Agreement" between MDD and StreamNow that was allegedly executed on or about March 15, 2024, and that purportedly covered more than 350 titles, including the 217 Aurelius titles at issue in this action. Ms. Yee's email stated, in relevant part, that StreamNow understood MDD to be an authorized distributor of Aurelius's content and that StreamNow had relied on MDD's representations in entering into the Content Distribution Agreement and in making the Aurelius titles available on its platform. As stated above, and as I have confirmed through exhaustive review of Aurelius's records, Aurelius has never granted MDD any rights to any Aurelius content. MDD's purported authority to license or sublicense Aurelius content is entirely fictitious and unauthorized. A true and correct copy of the November 3, 2025 email from Sandra Yee is attached hereto as Exhibit C.
9. The sole member and manager of Meridian Digital Distributors, LLC is Franklin Ogilvie. Mr. Ogilvie was formerly employed by Aurelius Media Americas, Inc. as a mid-level licensing manager from approximately June 2017 to June 30, 2021. During his employment, Mr. Ogilvie was involved in various aspects of Aurelius's content licensing operations, including the preparation of license agreements, management of content delivery workflows, and interaction with Aurelius's content management systems. Mr. Ogilvie's employment with AMA was terminated on June 30, 2021, following an internal investigation into unauthorized access to Aurelius's content management systems and associated records. The details of the internal investigation that led to Mr. Ogilvie's termination are documented in AMA's human resources files and are known to me based on my review of those records in connection with the present investigation. Upon his departure, Mr. Ogilvie executed a separation agreement dated June 30, 2021, which included, among other provisions, a non-compete clause, a non-solicitation clause, and an explicit prohibition on the use of any Aurelius intellectual property, trade secrets, confidential information, or proprietary materials following the termination of his employment.
Based on publicly available records maintained by the California Secretary of State, MDD was incorporated in late 2021 — approximately four to five months after Mr. Ogilvie's departure from Aurelius. I believe, based on the foregoing facts, that Mr. Ogilvie used knowledge, information, and familiarity with Aurelius's content library, licensing practices, and content management systems gained during his employment at Aurelius to falsely represent to StreamNow and potentially to other third parties that MDD had authority to license and distribute Aurelius content. The timing of MDD's formation, Mr. Ogilvie's prior role at Aurelius, and MDD's purported representation that it was authorized to distribute Aurelius content collectively support this belief.
10. The unauthorized availability of the 217 Aurelius titles on StreamNow's platform has been ongoing for approximately twenty-two months, from approximately April 1, 2024, through at least January 31, 2026, based on the analysis conducted by my team and confirmed through the forensic investigation performed by CipherTrace Analytics, LLC. During this entire period, the titles were made available for streaming to subscribers and, in many cases, to ad-supported users in the United States, Canada, Australia, and eleven additional territories — a total of fourteen countries. In addition to making the Aurelius content available directly on its own platform, StreamNow sublicensed bundles of content containing Aurelius titles to at least four third-party free ad-supported streaming television ("FAST") channel operators, thereby further expanding the unauthorized distribution of Aurelius's Works. The four downstream sublicensees identified to date are:
(1) Brindoval Channel Networks, Inc., a company based in Dallas, Texas;
(2) BrightLoop Media, LLC, a company based in Miami, Florida;
(3) Velvet Stream Partners, LP, an entity based in Toronto, Ontario, Canada; and
(4) Pacific Lantern Digital Pty Ltd, an entity based in Sydney, New South Wales, Australia.
Through StreamNow and these downstream sublicensees, Aurelius's copyrighted content has been made widely available to the public across multiple platforms and territories without any compensation to Aurelius and without Aurelius's knowledge or consent. The downstream sublicensing amplified the unauthorized distribution far beyond StreamNow's own platform, exponentially increasing the harm to Aurelius.
11. Based on my understanding of the analysis conducted by CipherTrace Analytics, LLC, the digital forensics and analytics firm retained by counsel in connection with this matter, StreamNow generated an estimated $38.6 million in total revenue attributable to the 217 Aurelius titles during the approximately twenty-two-month infringement period. This estimated total revenue comprises the following components:
(a) Subscription revenue: Approximately $22.4 million, based on a refined viewership share analysis with premium-tier weighting that attributes a proportional share of StreamNow's subscription revenue to viewership of Aurelius titles relative to total platform viewership;
(b) Advertising revenue (AVOD tier): Approximately $9.7 million, derived from advertising impressions and revenue generated by streams of Aurelius titles on StreamNow's free, ad-supported tier; and
(c) Sublicensing fees: Approximately $6.5 million, representing fees received by StreamNow from the four FAST channel operators identified in Paragraph 10 above for content bundles containing Aurelius titles.
None of this revenue — not a single dollar — has been shared with or paid to Aurelius. Aurelius has received zero compensation for the use of its content on StreamNow's platform or on any of the downstream sublicensee platforms. The full methodology and analysis underlying these revenue estimates are addressed in the separate declaration of Dr. Nathan Frey of CipherTrace Analytics, LLC, which is being filed concurrently with this declaration in support of Plaintiff's motion.
12. The unauthorized availability of Aurelius content on StreamNow's platform and the four FAST channel sublicensees has caused and continues to cause irreparable harm to Aurelius's licensing program in several significant and compounding ways:
(a) Erosion of Licensing Value. Aurelius licenses its content to authorized streaming platforms and distributors through carefully negotiated, arm's-length agreements that reflect the specific commercial value of each title, the territory, the term, the exclusivity provisions, and other material terms. The fair market value of a comparable license for the 217 Works at Issue over a twenty-two-month period in the relevant territories is estimated at approximately $14.2 million, based on Aurelius's historical licensing rates and comparable transactions. StreamNow's unauthorized availability of the same content — at lower cost or no additional cost to consumers on StreamNow's platform — directly undermines Aurelius's ability to command fair market rates from authorized licensees. Prospective and existing licensees have less incentive to pay premium rates for content that is already available elsewhere on an unauthorized basis. This erosion of licensing value is ongoing and worsens with each day that the unauthorized availability continues.
(b) Loss of Exclusivity. Many of Aurelius's licensing agreements with authorized platforms include exclusivity provisions that guarantee the licensee sole access to specified Aurelius titles within defined territories and time windows. The unauthorized presence of Aurelius titles on StreamNow's platform and on the platforms of StreamNow's four downstream sublicensees directly jeopardizes Aurelius's existing exclusive license arrangements. Aurelius faces a real and substantial risk that authorized partners who have paid for exclusive rights will assert breach-of-exclusivity claims against Aurelius, seek price reductions or renegotiations of existing agreements, or decline to renew or enter into new agreements. This risk is not speculative — I am aware that at least one authorized licensing partner has already raised concerns informally about the availability of certain Aurelius titles on platforms other than those covered by the partner's exclusive license.
(c) Competitive Harm and Market Displacement. StreamNow's unauthorized offering competes directly with Aurelius's authorized distribution channels and with the platforms of Aurelius's authorized licensees. Consumers who access Aurelius content on StreamNow or on the downstream FAST channels are diverted from platforms where Aurelius receives proper compensation. This competitive displacement reduces the value of Aurelius's content to authorized partners and diminishes Aurelius's ability to generate revenue from its own content in the marketplace.
(d) Diminution of Content Value. Each day that the 217 Works at Issue remain available on unauthorized platforms, the perceived market value and freshness of the content diminishes. This is particularly harmful for tentpole franchises such as Meridian, Iron Compass, and Thornfield, where the timing and exclusivity of availability windows are critical to maximizing the commercial value of new and catalog releases. Unauthorized early or concurrent availability on competing platforms reduces consumer demand on authorized platforms and undermines the carefully orchestrated release and windowing strategies that Aurelius employs to maximize the long-term value of its content library.
13. Beyond the direct economic harms to Aurelius's licensing program, the unauthorized distribution of Aurelius content on StreamNow's platform and through the downstream sublicensees has caused and continues to cause significant reputational harm to Aurelius. Aurelius's reputation as a premium content provider — both among consumers and within the media and entertainment industry — depends on its ability to control the quality, presentation, and distribution of its works. Aurelius invests substantial resources in ensuring that its content is presented to audiences with high-quality encoding, appropriate metadata, accurate subtitles and closed captions, and a user experience that reflects the premium nature of the Aurelius brand.
StreamNow's unauthorized use raises serious and well-founded concerns about the quality of encoding, presentation, and user experience associated with Aurelius content on an unauthorized platform — matters over which Aurelius has no control and no ability to monitor or remediate. The unauthorized distribution also creates confusion among consumers and industry partners about the authorized sources of Aurelius content, damaging Aurelius's brand integrity and its relationships with authorized licensees and distribution partners who expect Aurelius to maintain strict control over where and how its content appears.
14. As of the date of this declaration, I have confirmed through continued monitoring by my team that Aurelius titles remain available on StreamNow's platform. The infringement is ongoing and continues to cause harm to Aurelius with each passing day. Each additional day of unauthorized availability results in further viewership of Aurelius content on unauthorized channels, further displacement of viewership from authorized platforms, further erosion of licensing value, and further reputational harm. Without immediate injunctive relief from this Court, Aurelius will continue to suffer irreparable harm that cannot be adequately compensated by monetary damages alone, because:
(a) The loss of licensing leverage and exclusivity value is difficult to quantify with precision, as it depends on the future behavior of existing and prospective licensing partners and on market conditions that are inherently uncertain;
(b) The competitive displacement of authorized partners is ongoing and compounding, and the resulting harm to Aurelius's commercial relationships cannot be fully captured in a damages calculation;
(c) The reputational harm and brand dilution caused by unauthorized distribution on platforms outside Aurelius's control cannot be reversed or adequately remedied by a post-trial monetary judgment; and
(d) New viewers continue to access Aurelius content through unauthorized channels every day, further depleting the available market for authorized distribution and diminishing the commercial value of future licensing opportunities.
15. While Aurelius intends to pursue the full measure of its actual damages, statutory damages where applicable, and the disgorgement of StreamNow's profits attributable to the unauthorized exploitation of Aurelius content, monetary damages alone are insufficient to compensate Aurelius for the ongoing and compounding harms described above. The harm to Aurelius's licensing relationships, exclusivity commitments, brand reputation, and future content value is inherently irreparable in nature. No amount of money awarded at the conclusion of this litigation can restore the licensing leverage that Aurelius has lost, repair the relationships with authorized partners that have been strained, undo the consumer confusion that has been created, or recover the diminished market value of content that has been widely available on unauthorized platforms for nearly two years. Only immediate injunctive relief — requiring StreamNow to cease all reproduction, distribution, public performance, and other exploitation of the 217 Aurelius Works at Issue and to remove all Aurelius content from its platform and from all sublicensed channels — can prevent further irreparable injury to Aurelius.
16. Aurelius invests significant resources in monitoring and enforcing its digital rights worldwide, and I oversee the dedicated team responsible for detecting unauthorized distribution of Aurelius content across digital platforms, websites, and services. Upon discovery of the StreamNow infringement, Aurelius acted promptly and diligently to investigate the matter and to pursue its legal rights. The following timeline reflects the key steps taken by Aurelius following the initial discovery:
• October 15, 2025: My team and I discovered the unauthorized presence of Aurelius titles on StreamNow's platform during routine digital rights monitoring activities.
• October 22, 2025: I escalated the matter to Fiona Hartwell, General Counsel of Aurelius, and a formal internal investigation was commenced under my supervision.
• November 3, 2025: Sandra Yee, VP of Content Acquisition at StreamNow, responded to Mr. Anantharam's inquiry, claiming that StreamNow had obtained the Aurelius content through a sublicense from MDD.
• November 18, 2025: Aurelius engaged Bexley Marsh Solicitors LLP, London, for a preliminary legal assessment under English law, given the potential cross-border implications of the infringement.
• December 5, 2025: Bexley Marsh recommended that Aurelius engage experienced United States litigation counsel to pursue enforcement of Aurelius's rights under U.S. copyright law, given that StreamNow is a U.S. entity, the infringing platform is operated from the United States, and the primary distribution occurs in U.S. territory.
• January 8, 2026: Aurelius contacted Calderwood & Harkness LLP in Los Angeles regarding potential representation.
• January 15, 2026: An initial consultation took place between Marcus Delgado, Partner at Calderwood & Harkness LLP, and Fiona Hartwell, General Counsel of Aurelius.
• February 12, 2026: Calderwood & Harkness LLP's engagement was formally opened under Matter Number 1017-00003, and the firm commenced its pre-filing investigation and preparation of this action.
• March 14, 2026 (target): Service of formal cease-and-desist and demand letter on StreamNow Holdings, Inc., concurrent with or immediately following the filing of this action and the instant motion for emergency injunctive relief.
Aurelius has pursued its rights diligently and without unreasonable delay at every stage following the initial discovery. The period between discovery and the filing of this action reflects the time necessarily required to conduct a thorough internal investigation, retain and consult with qualified counsel on both sides of the Atlantic, verify copyright registrations, engage forensic analysts, and prepare the comprehensive record necessary to support this motion.
17. The following exhibits are attached to or referenced in this declaration in support of the factual assertions set forth herein:
• Exhibit A: Representative screenshots of Aurelius titles appearing on StreamNow's platform, including title pages, promotional artwork, and metadata, captured during monitoring activities conducted by my team between October 15, 2025, and February 28, 2026.
• Exhibit B: Complete list of the 217 Works at Issue, including title, format (feature film or television series), number of episodes (for television series), and corresponding U.S. Copyright Office registration number(s), cross-referenced to the Copyright Registration Summary Report prepared by Lexington IP Services, Inc.
• Exhibit C: True and correct copy of the email from Sandra Yee, Vice President of Content Acquisition, StreamNow Holdings, Inc., to Raj Anantharam, Senior Vice President, Content Licensing & Distribution, Aurelius Global Media Group PLC, dated November 3, 2025.
• Exhibit D: Summary excerpts from Aurelius's licensing database confirming that no license, sublicense, distribution agreement, or other authorization has been granted to StreamNow Holdings, Inc. or to Meridian Digital Distributors, LLC with respect to any Aurelius content.
The full forensic analysis of StreamNow's revenue attributable to the unauthorized exploitation of Aurelius content, including the methodology, data sources, and conclusions of CipherTrace Analytics, LLC, is addressed in the separate declaration of Dr. Nathan Frey, Managing Director of CipherTrace Analytics, LLC, which is being filed concurrently with this declaration in support of Plaintiff's motion.
ATTESTATION
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
Executed on ____, 2026, at Los Angeles, California.
________________________________________
Lena Kowalski Head of Digital Rights Enforcement Aurelius Global Media Group PLC 45 Clarewood Place, London W1K 6TH, United Kingdom c/o Aurelius Media Americas, Inc. 1900 Avenue of the Stars, Suite 2200 Los Angeles, California 90067
Prepared by: Omar Siddiqui, Associate Calderwood & Harkness LLP 1999 Avenue of the Stars, Suite 3100 Los Angeles, California 90067 Telephone: (310) 555-7200
Email: osiddiqui@calderwoodharkness.com
Reviewed by: Wendy Schultz, Senior Associate Marcus Delgado, Partner
Matter No.: 1017-00003
DRAFT — Subject to revision prior to filing
AURELIUS GLOBAL MEDIA GROUP PLC, a public limited company organized under the laws of England and Wales, | Case No.: [To be assigned upon filing]
Plaintiff, | DECLARATION OF LENA KOWALSKI IN SUPPORT OF PLAINTIFF'S MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
v.
STREAMNOW HOLDINGS, INC., a Delaware corporation; MERIDIAN DIGITAL DISTRIBUTORS, LLC, a California limited liability company; and FRANKLIN OGILVIE, an individual,
Defendants.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION

DECLARATION OF LENA KOWALSKI

ATTESTATION

Record

Parties

Dates

Amounts