1017-00003 · Aurelius Global Media Group · Litigation Readiness

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION — LOS ANGELES

Filed: March 10, 2026

TABLE OF AUTHORITIES

Cases

Statutes

Rules

I. NOTICE OF MOTION

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that Plaintiffs Aurelius Global Media Group PLC ("Aurelius") and Aurelius Media Americas, Inc. ("AMA") (collectively, "Plaintiffs") hereby move this Court, pursuant to Federal Rules of Civil Procedure 65(a) and (b) and 17 U.S.C. § 502, for entry of a temporary restraining order and, following a hearing on a date to be set by this Court, a preliminary injunction against Defendants StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie ("Ogilvie") (collectively, "Defendants").

Plaintiffs respectfully request that this Court grant the following relief:

(a) An order requiring StreamNow Holdings, Inc. to immediately cease all reproduction, distribution, and public performance of 217 audiovisual works owned by Aurelius, as specifically identified in Exhibit A to the Complaint filed concurrently herewith;

(b) An order requiring StreamNow to remove all Aurelius content from the StreamNow platform and all sublicensed channels, including those operated by Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd, within forty-eight (48) hours of entry of the order;

(c) An order requiring Meridian Digital Distributors, LLC and Franklin Ogilvie to cease all purported licensing activity involving Aurelius content, including but not limited to any further sublicensing, licensing, or distribution of any audiovisual work owned by Aurelius or AMA; and

(d) Such other and further relief as the Court deems just and proper.

This Motion is made and based on this Notice of Motion, the accompanying Memorandum of Points and Authorities set forth below, the concurrently filed Declarations of Lena Kowalski and Dr. Nathan Frey (CipherTrace Analytics, LLC), all exhibits attached thereto, all pleadings and records on file in this action, and upon such oral argument as the Court may entertain at the hearing of this Motion.

Plaintiffs respectfully request that the Court hear this matter at the earliest available date and time, or, in the alternative, consider this application on an ex parte basis for entry of a temporary restraining order without notice, or on shortened time, with a request that the preliminary injunction hearing be set within fourteen (14) days of the issuance of any temporary restraining order, consistent with Federal Rule of Civil Procedure 65(b)(2).

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS' MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION

II. INTRODUCTION

This case involves the brazen, large-scale, unauthorized exploitation of one of the world's most valuable film and television libraries — carried out over nearly two years, across fourteen countries, and generating tens of millions of dollars in illicit revenue — all premised on a fraudulent license from a company that never had any authority to grant one.

Plaintiff Aurelius Global Media Group PLC is a UK-headquartered public media conglomerate listed on the London Stock Exchange's AIM market (LSE AIM: AGLM). With fiscal year 2025 revenue of approximately £1.87 billion (approximately $2.36 billion), Aurelius owns and controls a library of more than 4,200 film and television titles, including some of the most recognizable and critically acclaimed properties in international entertainment. Among its marquee franchises are the "Meridian" franchise (six feature films with combined worldwide box office receipts of $1.43 billion), the "Iron Compass" series (four seasons, 48 episodes, averaging 9.2 million viewers per episode in the United Kingdom), and the celebrated "Thornfield" period drama catalog (twelve titles, seven BAFTA awards). Through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), Aurelius licenses and distributes its content throughout the United States and the Americas, generating substantial revenues from authorized partnerships with leading streaming platforms, broadcast networks, and theatrical exhibitors.

Defendant StreamNow Holdings, Inc. is a privately held Delaware corporation headquartered in Los Angeles, California, at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. StreamNow operates a "super-aggregator" streaming platform that bundles content from studios and independent distributors into subscription and advertising-supported tiers, available in fourteen countries. StreamNow is majority-owned (approximately 62% on a fully diluted basis) by Pinnacle Ventures Fund III, LP, which invested $145 million in a Series C financing round that closed in June 2022. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million.

Over a twenty-two-month period — from approximately April 1, 2024 through January 31, 2026, and continuing to the present — StreamNow has reproduced, distributed, and publicly performed 217 audiovisual works owned by Aurelius and AMA. Those works include 142 feature films and 75 television series comprising a total of 1,038 individual episodes. StreamNow has done so without any authorization from Aurelius. None. The works were ingested into StreamNow's platform library, made available to subscribers across the United States, Canada, Australia, and eleven additional international territories, and further sublicensed in content bundles to at least four third-party FAST (Free Ad-Supported Streaming Television) channel operators. The total attributable revenue that StreamNow has derived from this unauthorized exploitation of Aurelius's content is estimated at $38.6 million.

StreamNow purports to derive its rights from a "Content Distribution Agreement" dated March 15, 2024, executed with Defendant Meridian Digital Distributors, LLC ("MDD"). MDD is a California limited liability company controlled by Defendant Franklin Ogilvie — a former mid-level licensing manager at Aurelius Media Americas, Inc. whose employment was terminated on June 30, 2021 following an internal investigation into his unauthorized access to Aurelius's content management systems. Ogilvie's separation agreement, executed on that same date, expressly prohibited the use of any Aurelius intellectual property. MDD was incorporated in late 2021, shortly after Ogilvie's departure from AMA.

The central, inescapable fact of this case is this: Aurelius never granted MDD any license, sublicense, or distribution authority of any kind. MDD had no rights to convey. Consequently, StreamNow received no rights. The Content Distribution Agreement between MDD and StreamNow is, as to Aurelius's works, a nullity — a license built on sand.

The infringement is ongoing. It is massive in scale. And it is causing irreparable harm to Aurelius's licensing program, its content value, its market position, and its relationships with authorized distribution partners. Without the immediate injunctive relief sought herein, Aurelius will continue to suffer harm that cannot be remedied by monetary damages alone. Plaintiffs respectfully urge this Court to act swiftly to halt the ongoing infringement and preserve the status quo pending a full adjudication on the merits.

III. STATEMENT OF FACTS

A. The Parties

1. Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. Plaintiff Aurelius Global Media Group PLC ("Aurelius") is a public limited company organized under the laws of England and Wales, 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. Aurelius is one of the largest independent media conglomerates in Europe, with global operations spanning film and television production, distribution, licensing, and theatrical exhibition.

For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). Aurelius owns and controls a content library of over 4,200 film and television titles, spanning genres from blockbuster franchise filmmaking to critically acclaimed television drama and documentary programming. The company's senior leadership includes Chief Executive Officer Sir Alistair Pemberton, General Counsel Fiona Hartwell, Senior Vice President of Content Licensing & Distribution Raj Anantharam, and Head of Digital Rights Enforcement Lena Kowalski.

Plaintiff Aurelius Media Americas, Inc. ("AMA") is a corporation organized under the laws of the State of Delaware and is a wholly-owned subsidiary of Aurelius. AMA is headquartered at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as the operational arm of Aurelius's content licensing and distribution business throughout the United States and the Americas. AMA holds registered copyrights in numerous audiovisual works and administers the U.S. and hemispheric licensing program on behalf of Aurelius, which generates significant and recurring revenue from authorized distribution agreements with major streaming platforms, broadcast networks, cable operators, and theatrical exhibitors.

The Aurelius content library at issue in this litigation includes some of the most commercially successful and critically recognized properties in the global entertainment industry. Key franchises include:

• The "Meridian" franchise: Six feature films released between 2011 and 2024, with combined worldwide box office receipts of $1.43 billion. The franchise has generated additional hundreds of millions of dollars through home entertainment, merchandise licensing, and downstream distribution.

• The "Iron Compass" series: A four-season, 48-episode espionage thriller that aired on Severin Enterprises from 2018 through 2023, averaging 9.2 million viewers per episode in the United Kingdom and licensed for distribution in over 80 territories worldwide.

• The "Thornfield" period drama catalog: A collection of twelve award-winning period films and limited series, the recipients of seven BAFTA awards, widely regarded as cornerstone titles in the premium drama segment.

Through its authorized licensing program, Aurelius and AMA carefully manage the availability of these and other titles across distribution windows — theatrical, home entertainment, pay television, subscription video-on-demand ("SVOD"), and free ad-supported streaming television ("FAST") — to maximize the value of each title and protect the integrity of the Aurelius brand.

2. StreamNow Holdings, Inc. Defendant StreamNow Holdings, Inc. ("StreamNow") is a corporation organized under the laws of the State of Delaware, bearing Delaware Division of Corporations File Number 7291843, and is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow's registered agent is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.

StreamNow was founded in 2019 and is led by 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. StreamNow is a privately held company; its largest shareholder, holding approximately 62% of the company's equity on a fully diluted basis, is Pinnacle Ventures Fund III, LP, a venture capital fund managed by Pinnacle Ventures Management III, LLC, whose Managing Partner is Howard Cheng. Pinnacle Ventures Fund III, LP invested $145 million in StreamNow's Series C financing round, which closed in June 2022.

StreamNow operates what it describes as a "super-aggregator" streaming platform. The platform bundles content acquired from studios, independent distributors, and other content providers into multiple subscription and advertising-supported tiers, and makes that content available to consumers in fourteen countries. In addition to its direct-to-consumer streaming service, StreamNow sublicenses curated content bundles to third-party FAST channel operators, expanding the reach — and, in this case, the scope of infringement — of its content catalog. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million.

StreamNow is represented in this matter by outside counsel Grantham Roth & Pearce LLP, including Victoria Langford, partner, and Brian Matsuda, associate, at 555 South Flower Street, Suite 4200, Los Angeles, California 90071.

3. Meridian Digital Distributors, LLC and Franklin Ogilvie. Defendant Meridian Digital Distributors, LLC ("MDD") is a California limited liability company, registered with the California Secretary of State under File Number 202115729430, with its principal office located at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.

Defendant Franklin Ogilvie is the sole member and manager of MDD. Mr. Ogilvie is an individual residing in Los Angeles County, California. Prior to forming MDD, Ogilvie was employed by Aurelius Media Americas, Inc. from approximately 2017 through June 30, 2021, serving as a mid-level licensing manager within AMA's content distribution division. In that capacity, Ogilvie had access to Aurelius's proprietary content management systems, including internal databases cataloging title metadata, licensing terms, territorial availability, and rights holder information.

Ogilvie's employment with AMA was terminated effective June 30, 2021, following an internal investigation that revealed Ogilvie had engaged in unauthorized access to certain restricted areas of Aurelius's content management systems. The precise scope and purpose of Ogilvie's unauthorized access were documented in the investigation file maintained by AMA's Human Resources department and reviewed by AMA's General Counsel at the time.

On June 30, 2021, in connection with his departure, Ogilvie executed a separation agreement that included, among other provisions, a non-competition clause, a non-solicitation clause, a confidentiality provision, and an explicit and unambiguous prohibition on the use of any Aurelius intellectual property, including but not limited to copyrighted works, trademarks, trade secrets, and proprietary data. Declaration of Lena Kowalski ("Kowalski Decl."), ¶ 14; Exhibit B to Kowalski Decl. (Separation Agreement, redacted).

MDD was incorporated as a California limited liability company in late 2021 — only months after Ogilvie's departure from AMA. Aurelius has conducted a thorough search of its corporate records, licensing agreements, correspondence files, and internal databases, and has confirmed that Aurelius has never granted MDD any license, sublicense, or distribution authority over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17. No agreement exists. No authorization was given. No correspondence was exchanged. MDD's purported authority to license Aurelius's content is entirely fabricated.

B. Aurelius's Copyrighted Works

The 217 audiovisual works at issue in this action consist of 142 feature films and 75 television series comprising a total of 1,038 individual episodes. The complete list of works is set forth in Exhibit A to the Complaint filed concurrently herewith. These works represent a significant cross-section of Aurelius's content library and include many of its most valuable and commercially significant properties.

Among the works at issue are the following key franchises and titles:

• The "Meridian" franchise: Six feature films with combined worldwide box office receipts of $1.43 billion, representing one of the highest-grossing independent film franchises of the past decade.

• The "Iron Compass" series: Four seasons, 48 episodes, averaging 9.2 million UK viewers per episode, with licensing deals in over 80 territories.

• The "Thornfield" period drama catalog: Twelve titles, recipients of seven BAFTA awards, widely considered among the finest period dramas produced in the United Kingdom in the 21st century.

With respect to copyright registration, Plaintiffs submit the following:

Of the 217 titles at issue, 189 titles were timely registered with the U.S. Copyright Office — that is, they were registered either within three months of first publication or prior to the commencement of infringement, whichever is applicable. Pursuant to 17 U.S.C. §§ 504(c) and 505, these 189 timely-registered works are eligible for statutory damages and an award of attorneys' fees. An additional 28 titles were registered between May 2024 and October 2025, following the commencement of the infringing activity. These 28 works remain eligible for an award of actual damages and the infringer's profits under 17 U.S.C. § 504(b), though they are not eligible for statutory damages or attorneys' fees.

Verification of the copyright registration status for all 217 works was completed on January 22, 2026, by Lexington IP Services, Inc., under the direction of Marissa Chung, Director of Copyright Research. The resulting Copyright Registration Summary Report is attached as Exhibit C to the Declaration of Lena Kowalski. Additionally, a comprehensive chain-of-title analysis was conducted for all 217 works, confirming that Aurelius and/or AMA hold clear and unbroken ownership of all rights in each work. No gaps, encumbrances, or competing claims were identified. The Chain-of-Title Memorandum is attached as Exhibit D to the Declaration of Lena Kowalski.

C. The Unauthorized Distribution

On or about March 15, 2024, MDD and StreamNow purportedly executed a "Content Distribution Agreement" (the "MDD-StreamNow Agreement") under which MDD represented that it held distribution rights to a catalog of more than 350 titles, including all 217 Aurelius works at issue in this action. Kowalski Decl. ¶ 20. Aurelius was not a party to the MDD-StreamNow Agreement. Aurelius had no knowledge of the MDD-StreamNow Agreement at the time of its execution. Aurelius never authorized MDD to negotiate, execute, or perform any such agreement on its behalf.

Beginning approximately April 1, 2024, StreamNow ingested the 217 Aurelius titles into its platform library. This ingestion process involved the reproduction of the complete audiovisual works — each film in its entirety, each episode of each television series — onto StreamNow's servers and content delivery infrastructure. Following ingestion, StreamNow made the 217 Aurelius titles available for streaming to its subscribers in the United States, Canada, Australia, and eleven additional international territories. The works were distributed across both StreamNow's subscription tier and its advertising-supported (AVOD) tier. StreamNow also incorporated the Aurelius titles into curated content bundles that it sublicensed to at least four third-party FAST channel operators:

• Brindoval Channel Networks, Inc., headquartered in Dallas, Texas;

• BrightLoop Media, LLC, headquartered in Miami, Florida;

• Velvet Stream Partners, LP, headquartered in Toronto, Ontario, Canada; and

• Pacific Lantern Digital Pty Ltd, headquartered in Sydney, New South Wales, Australia.

Through these sublicensing arrangements, Aurelius's copyrighted works were further distributed to additional audiences, on additional platforms, in additional territories — all without any authorization from or payment to Aurelius.

Aurelius has never executed a license agreement with StreamNow. Aurelius has never authorized any intermediary, distributor, agent, or other entity to sublicense Aurelius content to StreamNow. Aurelius's records contain no agreement, authorization, memorandum of understanding, term sheet, or correspondence of any kind granting MDD, Ogilvie, or StreamNow any distribution rights over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17, 21–23.

D. Discovery of the Infringement and Investigation

Aurelius first became aware of the infringement on October 15, 2025, when Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, discovered multiple Aurelius titles streaming on StreamNow's platform during a routine audit of unauthorized digital distribution. Kowalski Decl. ¶ 24. Upon further investigation, Ms. Kowalski identified additional Aurelius titles on the platform and determined that the scope of the unauthorized distribution was far broader than initially apparent. Id. ¶ 25.

On October 22, 2025, Ms. Kowalski escalated the matter to Aurelius's General Counsel, Fiona Hartwell. Ms. Hartwell authorized a full internal investigation, which confirmed that Aurelius had never authorized MDD, StreamNow, or any other entity to distribute the affected titles. Kowalski Decl. ¶ 26.

On November 3, 2025, Aurelius's Senior Vice President of Content Licensing & Distribution, Raj Anantharam, directed an informal inquiry to StreamNow seeking an explanation for the presence of Aurelius content on the StreamNow platform. Sandra Yee, StreamNow's Vice President of Content Acquisition, responded to Mr. Anantharam's inquiry, claiming that StreamNow's distribution of the titles was authorized under its Content Distribution Agreement with MDD. Kowalski Decl. ¶ 27; Exhibit E to Kowalski Decl. (email correspondence between Anantharam and Yee, November 3, 2025). At no point did StreamNow offer to remove the content or suspend distribution pending resolution of the dispute. To the contrary, StreamNow continued its unauthorized exploitation of the 217 titles without interruption.

On November 18, 2025, Aurelius engaged Bexley Marsh Solicitors LLP, its UK counsel, for a preliminary legal assessment of the infringement and its implications under both UK and international copyright law. On December 5, 2025, Bexley Marsh recommended the engagement of U.S. counsel for the pursuit of U.S. copyright infringement claims, given that the primary infringing activity was conducted from StreamNow's Los Angeles headquarters and directed at U.S. and international audiences from U.S.-based infrastructure.

On January 8, 2026, Aurelius contacted Calderwood & Harkness LLP. An initial consultation between Marcus Delgado, partner at Calderwood & Harkness, and Fiona Hartwell took place on January 15, 2026. Following the completion of a conflicts check and a preliminary review of the factual record, Calderwood & Harkness's engagement was formally opened on February 12, 2026, under Matter Number 1017-00003.

In connection with this litigation, Aurelius retained CipherTrace Analytics, LLC, a digital media forensics firm based at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025, to conduct a comprehensive forensic analysis of the StreamNow platform. Dr. Nathan Frey, CipherTrace's Director of Digital Media Forensics, led the investigation. Using proprietary content fingerprinting technology and metadata extraction protocols, CipherTrace confirmed the presence of all 217 Aurelius titles on the StreamNow platform and verified that the works available on StreamNow are identical digital copies of the Aurelius originals. Declaration of Dr. Nathan Frey ("Frey Decl."), ¶¶ 8–15. CipherTrace further documented the availability of Aurelius content on the platforms of the four sublicensed FAST channel operators identified above. Frey Decl. ¶¶ 16–19.

E. Revenue and Damages

CipherTrace's forensic analysis determined that StreamNow derived a total of approximately $38.6 million in attributable revenue from the unauthorized distribution of Aurelius content over the twenty-two-month period from April 2024 through January 2026. Frey Decl. ¶¶ 20–29. This total was derived from three principal revenue streams:

• Subscription revenue: $22.4 million. This figure was calculated using a refined attribution model that adjusts for premium-tier weighting based on Aurelius titles comprising 7.18% of total StreamNow streams during the relevant period, applied proportionally to StreamNow's total subscription revenue. Frey Decl. ¶¶ 22–24.

• Advertising revenue (AVOD tier): $9.7 million. This figure reflects advertising revenue generated from ad impressions served during the streaming of Aurelius content on StreamNow's ad-supported tier. Frey Decl. ¶¶ 25–26.

• Sublicensing fees from FAST channel operators: $6.5 million. This figure represents fees paid to StreamNow by its four sublicensee FAST channel operators (Brindoval, BrightLoop, Velvet Stream, and Pacific Lantern) for content bundles that included Aurelius titles. Frey Decl. ¶¶ 27–29.

In addition to CipherTrace's revenue attribution analysis, Aurelius retained Hargrove Economic Consulting Group, LLC, to provide a preliminary assessment of damages. Dr. Elena Vasquez, a principal at Hargrove, estimated Aurelius's lost licensing revenue — defined as the fair market value of a comparable license for the 217 titles over the twenty-two-month period, based on comparable transactions in the marketplace — at approximately $14.2 million. Dr. Vasquez's preliminary total net recoverable damages estimate, calculated as actual damages plus the infringer's profits (with appropriate apportionment to avoid double-counting consistent with 17 U.S.C. § 504(b)), is approximately $41.3 million.

As an alternative to actual damages and profits, for the 189 timely-registered works, Aurelius is entitled to elect statutory damages under 17 U.S.C. § 504(c). If the Court determines that the infringement was willful — as the facts overwhelmingly demonstrate — statutory damages of up to $150,000 per work would yield a maximum statutory damages award of $32,550,000 for those 189 works alone (189 × $150,000 = $28,350,000), and the remaining 28 works for which only actual damages are available would add to the total recovery.

Critically, the infringement remains ongoing. StreamNow has not removed the Aurelius titles from its platform. StreamNow has not directed its sublicensees to remove the content. Each additional day of unauthorized streaming compounds Aurelius's losses and deepens the irreparable harm described more fully below.

IV. LEGAL STANDARD

Under Federal Rule of Civil Procedure 65 and well-established Ninth Circuit precedent, a plaintiff seeking a temporary restraining order or preliminary injunction must demonstrate: (1) a likelihood of success on the merits; (2) a likelihood that the plaintiff will suffer irreparable harm in the absence of preliminary relief; (3) that the balance of equities tips in the plaintiff's favor; and (4) that an injunction is in the public interest. Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20 (2008).

The Ninth Circuit has recognized that these factors exist on a sliding scale, such that "a stronger showing of one element may offset a weaker showing of another." Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011). However, the movant "must establish that irreparable harm is likely, not merely possible." Winter, 555 U.S. at 22.

In copyright cases, the Ninth Circuit has consistently held that a showing of likelihood of success on the merits of a copyright infringement claim raises a strong presumption of irreparable harm. A&M Records, Inc. v. Napster, Inc., 239 F.3d 1004, 1029 (9th Cir. 2001); Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848, 865–66 (9th Cir. 2017). Courts regularly grant preliminary injunctions — and temporary restraining orders — to halt ongoing copyright infringement, recognizing that the continued unauthorized exploitation of copyrighted works inflicts harm that monetary damages alone cannot remedy.

Section 502(a) of the Copyright Act provides that "[a]ny court having jurisdiction of a civil action arising under this title may . . . grant temporary and final injunctions on such terms as it may deem reasonable to prevent or restrain infringement of a copyright." 17 U.S.C. § 502(a). This statutory authorization reflects Congress's determination that injunctive relief is an essential tool for the protection of copyright holders' exclusive rights. The legislative history of the Copyright Act confirms that Congress intended courts to exercise their equitable powers broadly to prevent ongoing and future infringement.

V. ARGUMENT

A. Aurelius Is Likely to Succeed on the Merits

To establish copyright infringement under 17 U.S.C. § 501, a plaintiff must prove two elements: "(1) ownership of a valid copyright, and (2) copying of constituent elements of the work that are original." Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340, 361 (1991). As demonstrated below, Aurelius satisfies both elements with overwhelming force. Moreover, StreamNow has no valid license or other defense that could defeat Aurelius's claims, and its infringement is willful. Additional claims for contributory infringement and inducement lie against MDD and Ogilvie.

1. Aurelius Owns Valid Copyrights in the Works at Issue. Aurelius and AMA hold valid U.S. copyright registrations for all 217 audiovisual works at issue. Of these, 189 titles were timely registered with the U.S. Copyright Office — meaning they were registered either within three months of first publication or before infringement commenced — and are therefore eligible for statutory damages and attorneys' fees pursuant to 17 U.S.C. §§ 504(c) and 505. The remaining 28 titles were registered between May 2024 and October 2025, after the infringement began, and are eligible for actual damages and profits under 17 U.S.C. § 504(b).

A certificate of copyright registration constitutes prima facie evidence of the validity of the copyright and of the facts stated in the certificate. 17 U.S.C. § 410(c). The presumption of validity that attaches to a copyright registration shifts to the defendant the burden of producing evidence to rebut the presumption, and no such rebuttal evidence exists here.

The copyright registration status for all 217 works was verified by an independent third-party service, Lexington IP Services, Inc., under the direction of Marissa Chung, Director of Copyright Research, in a search completed on January 22, 2026. The resulting Copyright Registration Summary Report is attached as Exhibit C to the Kowalski Declaration. In addition, a comprehensive chain-of-title analysis was conducted for all 217 works, confirming that Aurelius and/or AMA hold unbroken chains of title for each work. No gaps, encumbrances, liens, competing claims, or unresolved assignments were identified. The Chain-of-Title Memorandum is attached as Exhibit D to the Kowalski Declaration.

There can be no genuine dispute that Aurelius owns valid copyrights in the 217 works at issue. This element is established conclusively.

2. StreamNow Has Copied, Distributed, and Publicly Performed the Works Without Authorization. StreamNow's conduct violates Aurelius's exclusive rights under the Copyright Act in at least three independently sufficient ways:

• Reproduction (17 U.S.C. § 106(1)): StreamNow reproduced each of the 217 works by copying them onto its servers, content delivery networks, and digital infrastructure. Each such reproduction constitutes a separate act of infringement.

• Distribution (17 U.S.C. § 106(3)): StreamNow distributed the 217 works to the public by making them available for streaming to subscribers in the United States, Canada, Australia, and eleven additional territories. StreamNow further distributed the works by sublicensing content bundles containing Aurelius titles to four third-party FAST channel operators.

• Public Performance (17 U.S.C. § 106(4)): StreamNow publicly performed the 217 works by transmitting them via its streaming platform to members of the public. Each individual streaming session constitutes a public performance of the copyrighted work.

Importantly, this is not a case involving allegations of substantial similarity or a dispute over the degree of copying. StreamNow did not borrow themes, draw inspiration from, or create works reminiscent of Aurelius's content. StreamNow reproduced and streamed the actual, complete audiovisual works — each film in full, each episode in full — verbatim, in their entirety, without alteration, to its subscribers and to the subscribers of its sublicensees.

The forensic analysis conducted by CipherTrace Analytics, LLC, and attested to in the Declaration of Dr. Nathan Frey, confirms beyond any reasonable question that the works available on the StreamNow platform are identical digital copies of the Aurelius originals. Frey Decl. ¶¶ 8–15. CipherTrace employed industry-standard content fingerprinting technology, which generates a unique digital signature for each audiovisual work and compares it against reference copies provided by Aurelius. The content fingerprinting analysis returned a 100% match for all 217 titles, confirming that the works on StreamNow's platform are exact reproductions of Aurelius's copyrighted works. Id. ¶ 12. CipherTrace additionally extracted and analyzed metadata associated with the StreamNow copies, further confirming their identity with the Aurelius originals. Id. ¶ 13.

The works have been made available in the United States, Canada, Australia, and eleven additional territories, reaching millions of consumers without any authorization from, or compensation to, the copyright holder. The works have been further sublicensed to four FAST channel operators — Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — multiplying the scope of the unauthorized distribution and the resulting harm to Aurelius.

The second element of copyright infringement — unauthorized copying of original elements — is established conclusively.

3. StreamNow Has No Valid License. StreamNow's sole claimed basis for its distribution of the 217 Aurelius works is the Content Distribution Agreement dated March 15, 2024, between StreamNow and MDD. This purported license provides StreamNow with no defense for two independent and dispositive reasons.

First, MDD had no rights to convey. It is a fundamental and well-established principle of copyright law that a sublicensee can acquire no greater rights than its licensor possesses. See, e.g., Jacobsen v. Katzer, 535 F.3d 1373, 1381–82 (Fed. Cir. 2008) (applying copyright principles). MDD was never granted any license, sublicense, or distribution authority by Aurelius — not in writing, not orally, not by implication, not by course of dealing, not by any means whatsoever. MDD's purported grant of rights to StreamNow was therefore a legal nullity. A party cannot convey rights it does not hold, and StreamNow, as the purported sublicensee, received nothing.

Second, MDD is controlled by Franklin Ogilvie, a former Aurelius employee whose employment was terminated on June 30, 2021, following an internal investigation into his unauthorized access to Aurelius's content management systems. The very entity purporting to license Aurelius's content is run by a former employee who was terminated for misconduct involving Aurelius's proprietary systems and who executed a separation agreement explicitly prohibiting the use of any Aurelius intellectual property. The circumstances under which MDD purported to license Aurelius's content strongly suggest that Ogilvie leveraged knowledge, access, and proprietary information obtained during his employment to create a fraudulent licensing scheme.

Aurelius's records contain no agreement, authorization, memorandum of understanding, term sheet, or correspondence of any kind granting MDD or Ogilvie any distribution rights over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17. The MDD-StreamNow Agreement, as applied to Aurelius's works, is a document that purports to grant rights that its grantor never held. It confers no authority on StreamNow and provides no defense to Aurelius's infringement claims.

Third, and independently, StreamNow's failure to conduct even the most basic due diligence on MDD's claimed authority underscores the absence of any good-faith basis for StreamNow's exploitation of Aurelius's content. StreamNow is a sophisticated content platform with estimated annual revenue of $312 million, backed by $145 million in institutional venture capital, staffed with experienced content acquisition professionals (including VP of Content Acquisition Sandra Yee), and represented by sophisticated outside counsel. Industry practice — and common sense — would have required StreamNow to verify MDD's authority by contacting Aurelius directly. A single phone call or email to Aurelius would have immediately revealed that MDD had no authority to license Aurelius's content. StreamNow's failure to take this elementary step is not a defense; it is evidence of willfulness, or at a minimum, reckless disregard for the rights of the copyright holder.

4. StreamNow Does Not Qualify for DMCA § 512 Safe Harbor. To the extent StreamNow might attempt to invoke the safe harbor provisions of the Digital Millennium Copyright Act, 17 U.S.C. § 512, any such defense would fail.

Section 512 provides a limited safe harbor from monetary liability for certain online service providers that passively host user-generated content and comply with specified notice-and-takedown procedures. The safe harbor was designed for platforms that serve as conduits for or hosts of content uploaded by third-party users, not for commercial enterprises that actively acquire, curate, license, monetize, and sublicense copyrighted content as the core of their business model.

StreamNow is not a passive hosting service. It does not host user-generated content. StreamNow actively curates its content catalog, negotiates and executes content distribution agreements with distributors, ingests content into its platform library pursuant to those agreements, assigns content to subscription and advertising-supported tiers, determines pricing structures, selects geographic availability across fourteen countries, and sublicenses curated content bundles to third-party FAST channel operators. StreamNow exercises pervasive editorial and commercial control over every aspect of its content catalog, from selection to monetization to sub-distribution.

StreamNow's business model as a "super-aggregator" — bundling and sublicensing content to FAST channel operators — is fundamentally different from the user-generated content platforms for which § 512 was designed. See Viacom Int'l, Inc. v. Crowne Albany Partners LLC, Inc., 676 F.3d 19, 38 (2d Cir. 2012) (discussing the contours of § 512 safe harbor); Columbia Pictures Indus., Inc. v. Fung, 710 F.3d 1020, 1040–43 (9th Cir. 2013) (denying safe harbor to defendant who actively participated in and induced infringement). StreamNow is the content distributor, not a neutral intermediary. It falls squarely outside the safe harbor provisions of § 512.

5. The Infringement Is Willful. The facts of this case support a finding that StreamNow's infringement of Aurelius's copyrights was willful, entitling Aurelius to enhanced statutory damages of up to $150,000 per work under 17 U.S.C. § 504(c)(2). Multiple independent facts support this conclusion.

First, StreamNow failed to conduct any reasonable due diligence on MDD's claimed authority to license the 217 Aurelius titles. In the content acquisition industry, it is standard practice for a platform acquiring content from a distributor to verify the distributor's authority by contacting the underlying rights holder. This is especially true for a catalog of the size and prominence of Aurelius's library — a library including globally recognized franchises like "Meridian" and "Iron Compass" — where the identity of the rights holder is well known throughout the industry. StreamNow made no effort to verify MDD's authority with Aurelius.

Second, Franklin Ogilvie's prior employment at Aurelius Media Americas was, or should have been, known to StreamNow through standard content acquisition vetting procedures. Any reasonable investigation into MDD's background — including a basic review of Ogilvie's Westmark Health IT profile, industry databases, or public records — would have revealed his prior employment at AMA and the obvious conflict of interest inherent in a former employee's company purporting to license his former employer's content catalog.

Third, the sheer scale of the infringement — 217 titles, 1,038 episodes, distributed in 14 countries, sublicensed to four FAST channel operators, generating $38.6 million in attributable revenue over 22 months — demonstrates a sustained and knowing pattern of exploitation. This was not an isolated or inadvertent incident. This was a systematic, large-scale, commercially motivated exploitation of Aurelius's content library.

Fourth, StreamNow is a sophisticated content platform with the resources, expertise, and industry-standard tools necessary to verify rights claims. StreamNow employs a dedicated VP of Content Acquisition (Sandra Yee) and outside counsel (Grantham Roth & Pearce LLP). It had every capacity and every incentive to conduct proper due diligence. Its failure to do so was, at a minimum, reckless, and more likely reflects a deliberate decision to look the other way.

Fifth, and perhaps most damningly, StreamNow continued its unauthorized exploitation of Aurelius's content even after Aurelius raised concerns. On November 3, 2025, Sandra Yee responded to Raj Anantharam's inquiry by claiming the MDD sublicense as authority — but StreamNow took no steps to verify that claim with Aurelius, to suspend distribution pending investigation, or to engage in any further dialogue. StreamNow continued to stream and sublicense the 217 titles without interruption, and has continued to do so to this day. This post-notice continuation of infringement strongly supports a finding of willfulness. See Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848, 857 (9th Cir. 2017).

6. Contributory and Inducement Claims Against MDD and Ogilvie. In addition to StreamNow's direct infringement, MDD and Franklin Ogilvie are liable for contributory infringement and inducement of infringement.

Contributory copyright infringement occurs where a party, "with knowledge of the infringing activity, induces, causes, or materially contributes to the infringing conduct of another." Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005); Perfect 10, Inc. v. Hollowell & Co., 508 F.3d 1146, 1171 (9th Cir. 2007). MDD and Ogilvie materially contributed to StreamNow's infringement by purporting to license content that MDD had no right to distribute and by supplying StreamNow with the digital copies of the works necessary to effectuate the infringement.

Inducement liability arises where a party distributes a device or, by analogy, provides content "with the object of promoting its use to infringe copyright, as shown by clear expression or other affirmative steps taken to foster infringement." Grokster, 545 U.S. at 936–37. MDD and Ogilvie did not merely facilitate StreamNow's infringement; they actively induced it by entering into the MDD-StreamNow Agreement, representing that MDD held distribution rights it did not possess, and providing StreamNow with the content necessary to carry out the infringement.

Ogilvie's conduct was knowing and deliberate. As a former AMA employee, Ogilvie was intimately familiar with Aurelius's content library. He knew that MDD had no authority to license Aurelius's content. He formed MDD shortly after his departure from AMA — a departure prompted by an investigation into his unauthorized access to Aurelius's systems — and proceeded to misrepresent MDD's rights in direct contravention of his separation agreement, which explicitly prohibited the use of any Aurelius intellectual property. Kowalski Decl. ¶ 14; Exhibit B. Ogilvie's conduct represents the most egregious form of copyright infringement: the knowing exploitation of a former employer's content library for personal financial gain.

B. Aurelius Will Suffer Irreparable Harm Absent Injunctive Relief

The irreparable harm to Aurelius from the continued unauthorized exploitation of its copyrighted works is manifest, ongoing, and compounding with each passing day. The Ninth Circuit has consistently held that a copyright holder's loss of control over its copyrighted works constitutes irreparable harm per se. Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d at 865–66; A&M Records, Inc. v. Napster, Inc., 239 F.3d at 1029. As the Ninth Circuit has explained, "the very nature of copyright infringement is that it causes irreparable injury because it undermines the right holder's control over the work." Camberwell & Co. v. Psystar Corp., 658 F.3d 1150, 1162 (9th Cir. 2011).

The infringement here is not historical or completed — it is ongoing. Every day, StreamNow continues to stream the 217 Aurelius works to its subscribers in fourteen countries. Every day, StreamNow's sublicensees continue to make Aurelius content available on their FAST channels. Every day, Aurelius's exclusive rights are violated anew. Every day, the harm compounds. The specific and concrete irreparable injuries to Aurelius include, but are not limited to, the following:

Loss of Licensing Value. The unauthorized availability of Aurelius content on StreamNow's platform, at price points and under commercial terms over which Aurelius has no control, demonstrably reduces Aurelius's licensing leverage with its authorized platform partners. The presence of the same content on an unauthorized and uncontrolled channel directly undermines Aurelius's ability to negotiate exclusive or premium-tier licensing deals, which constitute the economic foundation of its distribution business. Authorized licensees who have paid fair market value for Aurelius content — or who are in active negotiations for such content — are harmed by the knowledge that the same content is simultaneously available through unauthorized channels at unknown and potentially lower prices. This erosion of licensing leverage is a quintessential form of irreparable harm in the content industry, and it cannot be remedied after the fact by a monetary award. Kowalski Decl. ¶¶ 30–33.

Market Displacement. StreamNow's exploitation of Aurelius content in fourteen countries directly competes with and displaces Aurelius's authorized licensees in those same markets. When a consumer watches an Aurelius title on StreamNow, that consumer is — in many cases — a consumer who would otherwise have accessed the same title through an authorized channel. The resulting displacement of viewership from authorized to unauthorized channels reduces the value of Aurelius's authorized licensing deals and diminishes the revenue and engagement metrics that authorized licensees rely upon to justify their licensing fees. This competitive displacement is occurring in real time and cannot be reversed.

Reputational Harm. Aurelius's content is being distributed through a platform and through FAST channels over which Aurelius has no quality control, no editorial oversight, and no ability to manage its brand. Aurelius has invested decades in building and protecting its reputation as a premium content provider. The uncontrolled distribution of its works through unauthorized channels — where the presentation quality, advertising adjacency, and user experience may not meet Aurelius's standards — damages Aurelius's carefully cultivated brand and reputation. This form of harm is inherently difficult to quantify and cannot be adequately compensated through monetary damages.

Ongoing Revenue Loss. Each day of continued infringement adds to the $38.6 million in attributable revenue already generated by StreamNow from the unauthorized exploitation of Aurelius's content. The financial harm to Aurelius is not static; it grows with each passing day, as StreamNow continues to derive subscription revenue, advertising revenue, and sublicensing fees from content it has no right to exploit. While Aurelius will ultimately seek to recover these revenues as damages, the ongoing accrual of additional financial harm during the pendency of this litigation underscores the need for immediate injunctive relief.

Downstream Proliferation. StreamNow has sublicensed Aurelius content to four third-party FAST channel operators — Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — further multiplying the scope of the unauthorized distribution. Each additional sublicensee represents an additional point of distribution, an additional audience exposed to unauthorized copies, and an additional entity that must be brought into compliance. The proliferation of unauthorized copies through downstream sublicensing makes future enforcement more difficult, more expensive, and more time-consuming. The longer the infringement continues, the more deeply embedded Aurelius's content becomes in StreamNow's sublicensing ecosystem, and the more difficult it becomes to restore the status quo ante.

Monetary damages cannot adequately compensate Aurelius for the ongoing erosion of its exclusive rights, its licensing relationships, its content value, and its market position. The harm is not hypothetical. It is not speculative. It has been occurring for twenty-two months and it continues daily. The Court should not permit this state of affairs to persist.

C. The Balance of Equities Favors Aurelius

The balance of equities tips decisively in Aurelius's favor. On one side of the scale is the rightful owner of 217 copyrighted audiovisual works, which has never authorized their distribution through StreamNow or MDD, and which is suffering ongoing, compounding, irreparable harm to its exclusive rights, its licensing program, and its content value. On the other side is a commercial enterprise that has been distributing content it does not own and never validly licensed, generating $38.6 million in revenue from that unauthorized distribution.

An injunction would merely require StreamNow to stop doing what it had no right to do in the first place — distributing Aurelius's copyrighted content without authorization. This is not a case where the requested relief would force a defendant to surrender lawfully acquired rights or dismantle a legitimate business. StreamNow may continue to operate its streaming platform with the content it has lawfully licensed from other sources. The only content it would be required to remove is content it has no right to possess or distribute.

StreamNow's claimed reliance on the MDD-StreamNow Agreement does not create any equitable entitlement to continue infringing Aurelius's copyrights. StreamNow bears full responsibility for its failure to verify the source and validity of its purported rights. As a sophisticated commercial platform with access to experienced content acquisition professionals and outside counsel, StreamNow was in a position to conduct elementary due diligence. Its failure to do so does not generate equitable rights that could outweigh Aurelius's property interests. See Warner Bros. Entm't Inc. v. WTV Sys., Inc., 824 F. Supp. 2d 1003, 1012–13 (C.D. Cal. 2011) (balance of equities favors copyright holder where defendant's claimed reliance on purported license does not outweigh copyright holder's exclusive rights).

StreamNow will suffer no cognizable harm from being ordered to cease the unauthorized use of another party's property. There is no legally cognizable interest in continuing to infringe. Any interim economic burden on StreamNow — such as the loss of subscription and advertising revenue attributable to Aurelius titles — is entirely self-inflicted, resulting from StreamNow's decision to acquire and distribute content without proper authorization from the actual rights holder. StreamNow cannot be heard to complain that an injunction would deprive it of revenue it was never entitled to earn.

Against this, Aurelius faces continuing, compounding harm to its exclusive rights, its licensing program, its content value, and its relationships with authorized distribution partners with each passing day that the infringement continues. The equities overwhelmingly favor the entry of immediate injunctive relief.

D. An Injunction Serves the Public Interest

The public interest strongly favors the entry of injunctive relief in this case. The Copyright Act reflects a fundamental public policy determination — enshrined in the Copyright Clause of the United States Constitution, U.S. Const. art. I, § 8, cl. 8 — that creators and rights holders are entitled to control the distribution of their works. This constitutional and statutory framework is designed to "promote the Progress of Science and useful Arts" by providing creators with the exclusive rights necessary to incentivize the creation and dissemination of original works.

The enforcement of copyright serves the public interest in multiple, reinforcing ways. It incentivizes the creation of new works by ensuring that creators and rights holders can capture the economic value of their creative output. It protects the integrity and functioning of content markets by ensuring that content is distributed through authorized channels under agreed-upon terms. And it ensures fair competition by preventing unauthorized distributors from free-riding on the creative investments of others.

Permitting the ongoing unauthorized distribution of Aurelius's content would undermine the very licensing ecosystem that funds the creation of new film and television content — content that ultimately benefits the public. If sophisticated platforms like StreamNow can distribute content with impunity based on fraudulent licenses from unauthorized distributors, the economic incentives that drive content creation are eroded. The public has no interest in the continued availability of unlawfully distributed content through unauthorized channels; the public interest is served by ensuring that content reaches consumers through authorized, legitimate distribution channels.

Congress specifically authorized injunctive relief in copyright cases, providing in 17 U.S.C. § 502(a) that courts may "grant temporary and final injunctions on such terms as it may deem reasonable to prevent or restrain infringement of a copyright." This statutory authorization reflects Congress's considered judgment that the public interest is served by the prompt cessation of infringing activity. See Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d at 867–68 ("The public has a compelling interest in protecting copyright owners' marketable rights to their work and the authors' right to protect the integrity of the work." (citation omitted)).

The public interest factor weighs strongly in favor of injunctive relief.

VI. PLAINTIFFS ARE PREPARED TO POST AN APPROPRIATE BOND

Pursuant to Federal Rule of Civil Procedure 65(c), Plaintiffs are prepared to post a bond or other security in an amount the Court deems appropriate to compensate Defendants for any costs and damages they may sustain if the Court later determines that the injunction was wrongfully issued.

Given the overwhelming strength of Aurelius's ownership claims — substantiated by valid copyright registrations for all 217 works, an unbroken chain of title confirmed by independent analysis, and the complete absence of any colorable license or authorization — and given the total absence of any legitimate defense to the infringement claims, Plaintiffs respectfully submit that only a nominal bond is warranted. The risk that the injunction will ultimately be determined to have been wrongfully issued is vanishingly small. StreamNow has no valid license, no colorable safe harbor defense, and no basis in law or equity for its continued exploitation of Aurelius's content. MDD and Ogilvie had no authority whatsoever to license the works at issue.

Plaintiffs nonetheless stand ready to post whatever bond the Court may require in the exercise of its sound discretion.

VII. CONCLUSION AND PRAYER FOR RELIEF

For all of the foregoing reasons, Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. have demonstrated: (1) a strong likelihood of success on the merits of their claims for copyright infringement, contributory infringement, and inducement of infringement; (2) a likelihood of irreparable harm in the absence of preliminary relief, given the ongoing and compounding nature of the infringement; (3) that the balance of equities tips sharply in their favor, as an injunction would merely require Defendants to cease conduct they had no right to engage in; and (4) that the entry of an injunction serves the public interest in the enforcement of copyright law, the integrity of content markets, and the incentivization of creative expression.

WHEREFORE, Plaintiffs respectfully pray that this Court enter the following relief:

1. A temporary restraining order, effective immediately upon entry, requiring StreamNow Holdings, Inc. to cease all reproduction, distribution, and public performance of the 217 audiovisual works owned by Aurelius and identified in Exhibit A to the Complaint filed concurrently herewith;

2. A temporary restraining order requiring StreamNow Holdings, Inc. to remove all Aurelius content from the StreamNow platform and to direct all sublicensees — including Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — to remove all Aurelius content from their respective platforms within forty-eight (48) hours of service of the order;

3. A temporary restraining order requiring Meridian Digital Distributors, LLC and Franklin Ogilvie to immediately cease all purported licensing, sublicensing, or distribution of any audiovisual work owned by Aurelius Global Media Group PLC or Aurelius Media Americas, Inc.;

4. A preliminary injunction, following a hearing to be set by this Court, continuing the foregoing relief through the pendency of this action; and

5. Such other and further relief as the Court deems just and proper.

VIII. DECLARATIONS IN SUPPORT

The following declarations are filed concurrently herewith in support of this Motion and are incorporated herein by reference:

Declaration of Lena Kowalski

Ms. Kowalski serves as Head of Digital Rights Enforcement for Aurelius Global Media Group PLC. In her declaration, filed concurrently as a separate document, Ms. Kowalski attests to, among other things: her discovery of the infringement on October 15, 2025, during a routine audit of unauthorized digital distribution; her escalation of the matter to General Counsel Fiona Hartwell on October 22, 2025; the results of the internal investigation confirming that Aurelius never authorized MDD, StreamNow, or any other entity to distribute the works at issue; the scope of the infringement, encompassing 217 titles — including the "Meridian," "Iron Compass," and "Thornfield" franchises — consisting of 142 feature films and 75 television series comprising 1,038 episodes; the terms of Franklin Ogilvie's separation agreement, including its prohibition on the use of Aurelius intellectual property; and the ongoing and irreparable harm to Aurelius's licensing program, content value, and market position resulting from the continued unauthorized distribution.

Declaration of Dr. Nathan Frey

Dr. Frey serves as Director of Digital Media Forensics at CipherTrace Analytics, LLC, located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. In his declaration, filed concurrently as a separate document, Dr. Frey attests to, among other things: his professional qualifications and expertise in digital media forensics; the methodology employed by CipherTrace, including content fingerprinting technology and metadata extraction protocols; CipherTrace's confirmation that all 217 Aurelius titles are present and being actively streamed on the StreamNow platform; CipherTrace's verification that the works on StreamNow are identical digital copies of the Aurelius originals; CipherTrace's view

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION — LOS ANGELES
Filed: March 10, 2026
TABLE OF AUTHORITIES
Cases
Statutes
Rules
I. NOTICE OF MOTION
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiffs Aurelius Global Media Group PLC ("Aurelius") and Aurelius Media Americas, Inc. ("AMA") (collectively, "Plaintiffs") hereby move this Court, pursuant to Federal Rules of Civil Procedure 65(a) and (b) and 17 U.S.C. § 502, for entry of a temporary restraining order and, following a hearing on a date to be set by this Court, a preliminary injunction against Defendants StreamNow Holdings, Inc. ("StreamNow"), Meridian Digital Distributors, LLC ("MDD"), and Franklin Ogilvie ("Ogilvie") (collectively, "Defendants").
Plaintiffs respectfully request that this Court grant the following relief:
(a) An order requiring StreamNow Holdings, Inc. to immediately cease all reproduction, distribution, and public performance of 217 audiovisual works owned by Aurelius, as specifically identified in Exhibit A to the Complaint filed concurrently herewith;
(b) An order requiring StreamNow to remove all Aurelius content from the StreamNow platform and all sublicensed channels, including those operated by Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd, within forty-eight (48) hours of entry of the order;
(c) An order requiring Meridian Digital Distributors, LLC and Franklin Ogilvie to cease all purported licensing activity involving Aurelius content, including but not limited to any further sublicensing, licensing, or distribution of any audiovisual work owned by Aurelius or AMA; and
(d) Such other and further relief as the Court deems just and proper.
This Motion is made and based on this Notice of Motion, the accompanying Memorandum of Points and Authorities set forth below, the concurrently filed Declarations of Lena Kowalski and Dr. Nathan Frey (CipherTrace Analytics, LLC), all exhibits attached thereto, all pleadings and records on file in this action, and upon such oral argument as the Court may entertain at the hearing of this Motion.
Plaintiffs respectfully request that the Court hear this matter at the earliest available date and time, or, in the alternative, consider this application on an ex parte basis for entry of a temporary restraining order without notice, or on shortened time, with a request that the preliminary injunction hearing be set within fourteen (14) days of the issuance of any temporary restraining order, consistent with Federal Rule of Civil Procedure 65(b)(2).
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS' MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION
II. INTRODUCTION
This case involves the brazen, large-scale, unauthorized exploitation of one of the world's most valuable film and television libraries — carried out over nearly two years, across fourteen countries, and generating tens of millions of dollars in illicit revenue — all premised on a fraudulent license from a company that never had any authority to grant one.
Plaintiff Aurelius Global Media Group PLC is a UK-headquartered public media conglomerate listed on the London Stock Exchange's AIM market (LSE AIM: AGLM). With fiscal year 2025 revenue of approximately £1.87 billion (approximately $2.36 billion), Aurelius owns and controls a library of more than 4,200 film and television titles, including some of the most recognizable and critically acclaimed properties in international entertainment. Among its marquee franchises are the "Meridian" franchise (six feature films with combined worldwide box office receipts of $1.43 billion), the "Iron Compass" series (four seasons, 48 episodes, averaging 9.2 million viewers per episode in the United Kingdom), and the celebrated "Thornfield" period drama catalog (twelve titles, seven BAFTA awards). Through its wholly-owned Delaware subsidiary, Aurelius Media Americas, Inc. ("AMA"), Aurelius licenses and distributes its content throughout the United States and the Americas, generating substantial revenues from authorized partnerships with leading streaming platforms, broadcast networks, and theatrical exhibitors.
Defendant StreamNow Holdings, Inc. is a privately held Delaware corporation headquartered in Los Angeles, California, at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. StreamNow operates a "super-aggregator" streaming platform that bundles content from studios and independent distributors into subscription and advertising-supported tiers, available in fourteen countries. StreamNow is majority-owned (approximately 62% on a fully diluted basis) by Pinnacle Ventures Fund III, LP, which invested $145 million in a Series C financing round that closed in June 2022. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million.
Over a twenty-two-month period — from approximately April 1, 2024 through January 31, 2026, and continuing to the present — StreamNow has reproduced, distributed, and publicly performed 217 audiovisual works owned by Aurelius and AMA. Those works include 142 feature films and 75 television series comprising a total of 1,038 individual episodes. StreamNow has done so without any authorization from Aurelius. None. The works were ingested into StreamNow's platform library, made available to subscribers across the United States, Canada, Australia, and eleven additional international territories, and further sublicensed in content bundles to at least four third-party FAST (Free Ad-Supported Streaming Television) channel operators. The total attributable revenue that StreamNow has derived from this unauthorized exploitation of Aurelius's content is estimated at $38.6 million.
StreamNow purports to derive its rights from a "Content Distribution Agreement" dated March 15, 2024, executed with Defendant Meridian Digital Distributors, LLC ("MDD"). MDD is a California limited liability company controlled by Defendant Franklin Ogilvie — a former mid-level licensing manager at Aurelius Media Americas, Inc. whose employment was terminated on June 30, 2021 following an internal investigation into his unauthorized access to Aurelius's content management systems. Ogilvie's separation agreement, executed on that same date, expressly prohibited the use of any Aurelius intellectual property. MDD was incorporated in late 2021, shortly after Ogilvie's departure from AMA.
The central, inescapable fact of this case is this: Aurelius never granted MDD any license, sublicense, or distribution authority of any kind. MDD had no rights to convey. Consequently, StreamNow received no rights. The Content Distribution Agreement between MDD and StreamNow is, as to Aurelius's works, a nullity — a license built on sand.
The infringement is ongoing. It is massive in scale. And it is causing irreparable harm to Aurelius's licensing program, its content value, its market position, and its relationships with authorized distribution partners. Without the immediate injunctive relief sought herein, Aurelius will continue to suffer harm that cannot be remedied by monetary damages alone. Plaintiffs respectfully urge this Court to act swiftly to halt the ongoing infringement and preserve the status quo pending a full adjudication on the merits.
III. STATEMENT OF FACTS
A. The Parties
1. Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. Plaintiff Aurelius Global Media Group PLC ("Aurelius") is a public limited company organized under the laws of England and Wales, 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. Aurelius is one of the largest independent media conglomerates in Europe, with global operations spanning film and television production, distribution, licensing, and theatrical exhibition.
For fiscal year 2025, Aurelius reported consolidated revenue of approximately £1.87 billion (approximately $2.36 billion at prevailing exchange rates). Aurelius owns and controls a content library of over 4,200 film and television titles, spanning genres from blockbuster franchise filmmaking to critically acclaimed television drama and documentary programming. The company's senior leadership includes Chief Executive Officer Sir Alistair Pemberton, General Counsel Fiona Hartwell, Senior Vice President of Content Licensing & Distribution Raj Anantharam, and Head of Digital Rights Enforcement Lena Kowalski.
Plaintiff Aurelius Media Americas, Inc. ("AMA") is a corporation organized under the laws of the State of Delaware and is a wholly-owned subsidiary of Aurelius. AMA is headquartered at 1900 Avenue of the Stars, Suite 2200, Los Angeles, California 90067. AMA serves as the operational arm of Aurelius's content licensing and distribution business throughout the United States and the Americas. AMA holds registered copyrights in numerous audiovisual works and administers the U.S. and hemispheric licensing program on behalf of Aurelius, which generates significant and recurring revenue from authorized distribution agreements with major streaming platforms, broadcast networks, cable operators, and theatrical exhibitors.
The Aurelius content library at issue in this litigation includes some of the most commercially successful and critically recognized properties in the global entertainment industry. Key franchises include:
• The "Meridian" franchise: Six feature films released between 2011 and 2024, with combined worldwide box office receipts of $1.43 billion. The franchise has generated additional hundreds of millions of dollars through home entertainment, merchandise licensing, and downstream distribution.
• The "Iron Compass" series: A four-season, 48-episode espionage thriller that aired on Severin Enterprises from 2018 through 2023, averaging 9.2 million viewers per episode in the United Kingdom and licensed for distribution in over 80 territories worldwide.
• The "Thornfield" period drama catalog: A collection of twelve award-winning period films and limited series, the recipients of seven BAFTA awards, widely regarded as cornerstone titles in the premium drama segment.
Through its authorized licensing program, Aurelius and AMA carefully manage the availability of these and other titles across distribution windows — theatrical, home entertainment, pay television, subscription video-on-demand ("SVOD"), and free ad-supported streaming television ("FAST") — to maximize the value of each title and protect the integrity of the Aurelius brand.
2. StreamNow Holdings, Inc. Defendant StreamNow Holdings, Inc. ("StreamNow") is a corporation organized under the laws of the State of Delaware, bearing Delaware Division of Corporations File Number 7291843, and is headquartered at 3400 Wilshire Boulevard, Suite 1800, Los Angeles, California 90010. StreamNow's registered agent is Capitol Registered Agents, Inc., located at 1209 Orange Street, Wilmington, Delaware 19801.
StreamNow was founded in 2019 and is led by 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. StreamNow is a privately held company; its largest shareholder, holding approximately 62% of the company's equity on a fully diluted basis, is Pinnacle Ventures Fund III, LP, a venture capital fund managed by Pinnacle Ventures Management III, LLC, whose Managing Partner is Howard Cheng. Pinnacle Ventures Fund III, LP invested $145 million in StreamNow's Series C financing round, which closed in June 2022.
StreamNow operates what it describes as a "super-aggregator" streaming platform. The platform bundles content acquired from studios, independent distributors, and other content providers into multiple subscription and advertising-supported tiers, and makes that content available to consumers in fourteen countries. In addition to its direct-to-consumer streaming service, StreamNow sublicenses curated content bundles to third-party FAST channel operators, expanding the reach — and, in this case, the scope of infringement — of its content catalog. StreamNow's estimated fiscal year 2025 revenue was approximately $312 million.
StreamNow is represented in this matter by outside counsel Grantham Roth & Pearce LLP, including Victoria Langford, partner, and Brian Matsuda, associate, at 555 South Flower Street, Suite 4200, Los Angeles, California 90071.
3. Meridian Digital Distributors, LLC and Franklin Ogilvie. Defendant Meridian Digital Distributors, LLC ("MDD") is a California limited liability company, registered with the California Secretary of State under File Number 202115729430, with its principal office located at 8912 Burton Way, Suite 200, Beverly Hills, California 90211.
Defendant Franklin Ogilvie is the sole member and manager of MDD. Mr. Ogilvie is an individual residing in Los Angeles County, California. Prior to forming MDD, Ogilvie was employed by Aurelius Media Americas, Inc. from approximately 2017 through June 30, 2021, serving as a mid-level licensing manager within AMA's content distribution division. In that capacity, Ogilvie had access to Aurelius's proprietary content management systems, including internal databases cataloging title metadata, licensing terms, territorial availability, and rights holder information.
Ogilvie's employment with AMA was terminated effective June 30, 2021, following an internal investigation that revealed Ogilvie had engaged in unauthorized access to certain restricted areas of Aurelius's content management systems. The precise scope and purpose of Ogilvie's unauthorized access were documented in the investigation file maintained by AMA's Human Resources department and reviewed by AMA's General Counsel at the time.
On June 30, 2021, in connection with his departure, Ogilvie executed a separation agreement that included, among other provisions, a non-competition clause, a non-solicitation clause, a confidentiality provision, and an explicit and unambiguous prohibition on the use of any Aurelius intellectual property, including but not limited to copyrighted works, trademarks, trade secrets, and proprietary data. Declaration of Lena Kowalski ("Kowalski Decl."), ¶ 14; Exhibit B to Kowalski Decl. (Separation Agreement, redacted).
MDD was incorporated as a California limited liability company in late 2021 — only months after Ogilvie's departure from AMA. Aurelius has conducted a thorough search of its corporate records, licensing agreements, correspondence files, and internal databases, and has confirmed that Aurelius has never granted MDD any license, sublicense, or distribution authority over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17. No agreement exists. No authorization was given. No correspondence was exchanged. MDD's purported authority to license Aurelius's content is entirely fabricated.
B. Aurelius's Copyrighted Works
The 217 audiovisual works at issue in this action consist of 142 feature films and 75 television series comprising a total of 1,038 individual episodes. The complete list of works is set forth in Exhibit A to the Complaint filed concurrently herewith. These works represent a significant cross-section of Aurelius's content library and include many of its most valuable and commercially significant properties.
Among the works at issue are the following key franchises and titles:
• The "Meridian" franchise: Six feature films with combined worldwide box office receipts of $1.43 billion, representing one of the highest-grossing independent film franchises of the past decade.
• The "Iron Compass" series: Four seasons, 48 episodes, averaging 9.2 million UK viewers per episode, with licensing deals in over 80 territories.
• The "Thornfield" period drama catalog: Twelve titles, recipients of seven BAFTA awards, widely considered among the finest period dramas produced in the United Kingdom in the 21st century.
With respect to copyright registration, Plaintiffs submit the following:
Of the 217 titles at issue, 189 titles were timely registered with the U.S. Copyright Office — that is, they were registered either within three months of first publication or prior to the commencement of infringement, whichever is applicable. Pursuant to 17 U.S.C. §§ 504(c) and 505, these 189 timely-registered works are eligible for statutory damages and an award of attorneys' fees. An additional 28 titles were registered between May 2024 and October 2025, following the commencement of the infringing activity. These 28 works remain eligible for an award of actual damages and the infringer's profits under 17 U.S.C. § 504(b), though they are not eligible for statutory damages or attorneys' fees.
Verification of the copyright registration status for all 217 works was completed on January 22, 2026, by Lexington IP Services, Inc., under the direction of Marissa Chung, Director of Copyright Research. The resulting Copyright Registration Summary Report is attached as Exhibit C to the Declaration of Lena Kowalski. Additionally, a comprehensive chain-of-title analysis was conducted for all 217 works, confirming that Aurelius and/or AMA hold clear and unbroken ownership of all rights in each work. No gaps, encumbrances, or competing claims were identified. The Chain-of-Title Memorandum is attached as Exhibit D to the Declaration of Lena Kowalski.
C. The Unauthorized Distribution
On or about March 15, 2024, MDD and StreamNow purportedly executed a "Content Distribution Agreement" (the "MDD-StreamNow Agreement") under which MDD represented that it held distribution rights to a catalog of more than 350 titles, including all 217 Aurelius works at issue in this action. Kowalski Decl. ¶ 20. Aurelius was not a party to the MDD-StreamNow Agreement. Aurelius had no knowledge of the MDD-StreamNow Agreement at the time of its execution. Aurelius never authorized MDD to negotiate, execute, or perform any such agreement on its behalf.
Beginning approximately April 1, 2024, StreamNow ingested the 217 Aurelius titles into its platform library. This ingestion process involved the reproduction of the complete audiovisual works — each film in its entirety, each episode of each television series — onto StreamNow's servers and content delivery infrastructure. Following ingestion, StreamNow made the 217 Aurelius titles available for streaming to its subscribers in the United States, Canada, Australia, and eleven additional international territories. The works were distributed across both StreamNow's subscription tier and its advertising-supported (AVOD) tier. StreamNow also incorporated the Aurelius titles into curated content bundles that it sublicensed to at least four third-party FAST channel operators:
• Brindoval Channel Networks, Inc., headquartered in Dallas, Texas;
• BrightLoop Media, LLC, headquartered in Miami, Florida;
• Velvet Stream Partners, LP, headquartered in Toronto, Ontario, Canada; and
• Pacific Lantern Digital Pty Ltd, headquartered in Sydney, New South Wales, Australia.
Through these sublicensing arrangements, Aurelius's copyrighted works were further distributed to additional audiences, on additional platforms, in additional territories — all without any authorization from or payment to Aurelius.
Aurelius has never executed a license agreement with StreamNow. Aurelius has never authorized any intermediary, distributor, agent, or other entity to sublicense Aurelius content to StreamNow. Aurelius's records contain no agreement, authorization, memorandum of understanding, term sheet, or correspondence of any kind granting MDD, Ogilvie, or StreamNow any distribution rights over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17, 21–23.
D. Discovery of the Infringement and Investigation
Aurelius first became aware of the infringement on October 15, 2025, when Lena Kowalski, Aurelius's Head of Digital Rights Enforcement, discovered multiple Aurelius titles streaming on StreamNow's platform during a routine audit of unauthorized digital distribution. Kowalski Decl. ¶ 24. Upon further investigation, Ms. Kowalski identified additional Aurelius titles on the platform and determined that the scope of the unauthorized distribution was far broader than initially apparent. Id. ¶ 25.
On October 22, 2025, Ms. Kowalski escalated the matter to Aurelius's General Counsel, Fiona Hartwell. Ms. Hartwell authorized a full internal investigation, which confirmed that Aurelius had never authorized MDD, StreamNow, or any other entity to distribute the affected titles. Kowalski Decl. ¶ 26.
On November 3, 2025, Aurelius's Senior Vice President of Content Licensing & Distribution, Raj Anantharam, directed an informal inquiry to StreamNow seeking an explanation for the presence of Aurelius content on the StreamNow platform. Sandra Yee, StreamNow's Vice President of Content Acquisition, responded to Mr. Anantharam's inquiry, claiming that StreamNow's distribution of the titles was authorized under its Content Distribution Agreement with MDD. Kowalski Decl. ¶ 27; Exhibit E to Kowalski Decl. (email correspondence between Anantharam and Yee, November 3, 2025). At no point did StreamNow offer to remove the content or suspend distribution pending resolution of the dispute. To the contrary, StreamNow continued its unauthorized exploitation of the 217 titles without interruption.
On November 18, 2025, Aurelius engaged Bexley Marsh Solicitors LLP, its UK counsel, for a preliminary legal assessment of the infringement and its implications under both UK and international copyright law. On December 5, 2025, Bexley Marsh recommended the engagement of U.S. counsel for the pursuit of U.S. copyright infringement claims, given that the primary infringing activity was conducted from StreamNow's Los Angeles headquarters and directed at U.S. and international audiences from U.S.-based infrastructure.
On January 8, 2026, Aurelius contacted Calderwood & Harkness LLP. An initial consultation between Marcus Delgado, partner at Calderwood & Harkness, and Fiona Hartwell took place on January 15, 2026. Following the completion of a conflicts check and a preliminary review of the factual record, Calderwood & Harkness's engagement was formally opened on February 12, 2026, under Matter Number 1017-00003.
In connection with this litigation, Aurelius retained CipherTrace Analytics, LLC, a digital media forensics firm based at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025, to conduct a comprehensive forensic analysis of the StreamNow platform. Dr. Nathan Frey, CipherTrace's Director of Digital Media Forensics, led the investigation. Using proprietary content fingerprinting technology and metadata extraction protocols, CipherTrace confirmed the presence of all 217 Aurelius titles on the StreamNow platform and verified that the works available on StreamNow are identical digital copies of the Aurelius originals. Declaration of Dr. Nathan Frey ("Frey Decl."), ¶¶ 8–15. CipherTrace further documented the availability of Aurelius content on the platforms of the four sublicensed FAST channel operators identified above. Frey Decl. ¶¶ 16–19.
E. Revenue and Damages
CipherTrace's forensic analysis determined that StreamNow derived a total of approximately $38.6 million in attributable revenue from the unauthorized distribution of Aurelius content over the twenty-two-month period from April 2024 through January 2026. Frey Decl. ¶¶ 20–29. This total was derived from three principal revenue streams:
• Subscription revenue: $22.4 million. This figure was calculated using a refined attribution model that adjusts for premium-tier weighting based on Aurelius titles comprising 7.18% of total StreamNow streams during the relevant period, applied proportionally to StreamNow's total subscription revenue. Frey Decl. ¶¶ 22–24.
• Advertising revenue (AVOD tier): $9.7 million. This figure reflects advertising revenue generated from ad impressions served during the streaming of Aurelius content on StreamNow's ad-supported tier. Frey Decl. ¶¶ 25–26.
• Sublicensing fees from FAST channel operators: $6.5 million. This figure represents fees paid to StreamNow by its four sublicensee FAST channel operators (Brindoval, BrightLoop, Velvet Stream, and Pacific Lantern) for content bundles that included Aurelius titles. Frey Decl. ¶¶ 27–29.
In addition to CipherTrace's revenue attribution analysis, Aurelius retained Hargrove Economic Consulting Group, LLC, to provide a preliminary assessment of damages. Dr. Elena Vasquez, a principal at Hargrove, estimated Aurelius's lost licensing revenue — defined as the fair market value of a comparable license for the 217 titles over the twenty-two-month period, based on comparable transactions in the marketplace — at approximately $14.2 million. Dr. Vasquez's preliminary total net recoverable damages estimate, calculated as actual damages plus the infringer's profits (with appropriate apportionment to avoid double-counting consistent with 17 U.S.C. § 504(b)), is approximately $41.3 million.
As an alternative to actual damages and profits, for the 189 timely-registered works, Aurelius is entitled to elect statutory damages under 17 U.S.C. § 504(c). If the Court determines that the infringement was willful — as the facts overwhelmingly demonstrate — statutory damages of up to $150,000 per work would yield a maximum statutory damages award of $32,550,000 for those 189 works alone (189 × $150,000 = $28,350,000), and the remaining 28 works for which only actual damages are available would add to the total recovery.
Critically, the infringement remains ongoing. StreamNow has not removed the Aurelius titles from its platform. StreamNow has not directed its sublicensees to remove the content. Each additional day of unauthorized streaming compounds Aurelius's losses and deepens the irreparable harm described more fully below.
IV. LEGAL STANDARD
Under Federal Rule of Civil Procedure 65 and well-established Ninth Circuit precedent, a plaintiff seeking a temporary restraining order or preliminary injunction must demonstrate: (1) a likelihood of success on the merits; (2) a likelihood that the plaintiff will suffer irreparable harm in the absence of preliminary relief; (3) that the balance of equities tips in the plaintiff's favor; and (4) that an injunction is in the public interest. Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20 (2008).
The Ninth Circuit has recognized that these factors exist on a sliding scale, such that "a stronger showing of one element may offset a weaker showing of another." Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011). However, the movant "must establish that irreparable harm is likely, not merely possible." Winter, 555 U.S. at 22.
In copyright cases, the Ninth Circuit has consistently held that a showing of likelihood of success on the merits of a copyright infringement claim raises a strong presumption of irreparable harm. A&M Records, Inc. v. Napster, Inc., 239 F.3d 1004, 1029 (9th Cir. 2001); Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848, 865–66 (9th Cir. 2017). Courts regularly grant preliminary injunctions — and temporary restraining orders — to halt ongoing copyright infringement, recognizing that the continued unauthorized exploitation of copyrighted works inflicts harm that monetary damages alone cannot remedy.
Section 502(a) of the Copyright Act provides that "[a]ny court having jurisdiction of a civil action arising under this title may . . . grant temporary and final injunctions on such terms as it may deem reasonable to prevent or restrain infringement of a copyright." 17 U.S.C. § 502(a). This statutory authorization reflects Congress's determination that injunctive relief is an essential tool for the protection of copyright holders' exclusive rights. The legislative history of the Copyright Act confirms that Congress intended courts to exercise their equitable powers broadly to prevent ongoing and future infringement.
V. ARGUMENT
A. Aurelius Is Likely to Succeed on the Merits
To establish copyright infringement under 17 U.S.C. § 501, a plaintiff must prove two elements: "(1) ownership of a valid copyright, and (2) copying of constituent elements of the work that are original." Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340, 361 (1991). As demonstrated below, Aurelius satisfies both elements with overwhelming force. Moreover, StreamNow has no valid license or other defense that could defeat Aurelius's claims, and its infringement is willful. Additional claims for contributory infringement and inducement lie against MDD and Ogilvie.
1. Aurelius Owns Valid Copyrights in the Works at Issue. Aurelius and AMA hold valid U.S. copyright registrations for all 217 audiovisual works at issue. Of these, 189 titles were timely registered with the U.S. Copyright Office — meaning they were registered either within three months of first publication or before infringement commenced — and are therefore eligible for statutory damages and attorneys' fees pursuant to 17 U.S.C. §§ 504(c) and 505. The remaining 28 titles were registered between May 2024 and October 2025, after the infringement began, and are eligible for actual damages and profits under 17 U.S.C. § 504(b).
A certificate of copyright registration constitutes prima facie evidence of the validity of the copyright and of the facts stated in the certificate. 17 U.S.C. § 410(c). The presumption of validity that attaches to a copyright registration shifts to the defendant the burden of producing evidence to rebut the presumption, and no such rebuttal evidence exists here.
The copyright registration status for all 217 works was verified by an independent third-party service, Lexington IP Services, Inc., under the direction of Marissa Chung, Director of Copyright Research, in a search completed on January 22, 2026. The resulting Copyright Registration Summary Report is attached as Exhibit C to the Kowalski Declaration. In addition, a comprehensive chain-of-title analysis was conducted for all 217 works, confirming that Aurelius and/or AMA hold unbroken chains of title for each work. No gaps, encumbrances, liens, competing claims, or unresolved assignments were identified. The Chain-of-Title Memorandum is attached as Exhibit D to the Kowalski Declaration.
There can be no genuine dispute that Aurelius owns valid copyrights in the 217 works at issue. This element is established conclusively.
2. StreamNow Has Copied, Distributed, and Publicly Performed the Works Without Authorization. StreamNow's conduct violates Aurelius's exclusive rights under the Copyright Act in at least three independently sufficient ways:
• Reproduction (17 U.S.C. § 106(1)): StreamNow reproduced each of the 217 works by copying them onto its servers, content delivery networks, and digital infrastructure. Each such reproduction constitutes a separate act of infringement.
• Distribution (17 U.S.C. § 106(3)): StreamNow distributed the 217 works to the public by making them available for streaming to subscribers in the United States, Canada, Australia, and eleven additional territories. StreamNow further distributed the works by sublicensing content bundles containing Aurelius titles to four third-party FAST channel operators.
• Public Performance (17 U.S.C. § 106(4)): StreamNow publicly performed the 217 works by transmitting them via its streaming platform to members of the public. Each individual streaming session constitutes a public performance of the copyrighted work.
Importantly, this is not a case involving allegations of substantial similarity or a dispute over the degree of copying. StreamNow did not borrow themes, draw inspiration from, or create works reminiscent of Aurelius's content. StreamNow reproduced and streamed the actual, complete audiovisual works — each film in full, each episode in full — verbatim, in their entirety, without alteration, to its subscribers and to the subscribers of its sublicensees.
The forensic analysis conducted by CipherTrace Analytics, LLC, and attested to in the Declaration of Dr. Nathan Frey, confirms beyond any reasonable question that the works available on the StreamNow platform are identical digital copies of the Aurelius originals. Frey Decl. ¶¶ 8–15. CipherTrace employed industry-standard content fingerprinting technology, which generates a unique digital signature for each audiovisual work and compares it against reference copies provided by Aurelius. The content fingerprinting analysis returned a 100% match for all 217 titles, confirming that the works on StreamNow's platform are exact reproductions of Aurelius's copyrighted works. Id. ¶ 12. CipherTrace additionally extracted and analyzed metadata associated with the StreamNow copies, further confirming their identity with the Aurelius originals. Id. ¶ 13.
The works have been made available in the United States, Canada, Australia, and eleven additional territories, reaching millions of consumers without any authorization from, or compensation to, the copyright holder. The works have been further sublicensed to four FAST channel operators — Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — multiplying the scope of the unauthorized distribution and the resulting harm to Aurelius.
The second element of copyright infringement — unauthorized copying of original elements — is established conclusively.
3. StreamNow Has No Valid License. StreamNow's sole claimed basis for its distribution of the 217 Aurelius works is the Content Distribution Agreement dated March 15, 2024, between StreamNow and MDD. This purported license provides StreamNow with no defense for two independent and dispositive reasons.
First, MDD had no rights to convey. It is a fundamental and well-established principle of copyright law that a sublicensee can acquire no greater rights than its licensor possesses. See, e.g., Jacobsen v. Katzer, 535 F.3d 1373, 1381–82 (Fed. Cir. 2008) (applying copyright principles). MDD was never granted any license, sublicense, or distribution authority by Aurelius — not in writing, not orally, not by implication, not by course of dealing, not by any means whatsoever. MDD's purported grant of rights to StreamNow was therefore a legal nullity. A party cannot convey rights it does not hold, and StreamNow, as the purported sublicensee, received nothing.
Second, MDD is controlled by Franklin Ogilvie, a former Aurelius employee whose employment was terminated on June 30, 2021, following an internal investigation into his unauthorized access to Aurelius's content management systems. The very entity purporting to license Aurelius's content is run by a former employee who was terminated for misconduct involving Aurelius's proprietary systems and who executed a separation agreement explicitly prohibiting the use of any Aurelius intellectual property. The circumstances under which MDD purported to license Aurelius's content strongly suggest that Ogilvie leveraged knowledge, access, and proprietary information obtained during his employment to create a fraudulent licensing scheme.
Aurelius's records contain no agreement, authorization, memorandum of understanding, term sheet, or correspondence of any kind granting MDD or Ogilvie any distribution rights over any Aurelius-owned content. Kowalski Decl. ¶¶ 15–17. The MDD-StreamNow Agreement, as applied to Aurelius's works, is a document that purports to grant rights that its grantor never held. It confers no authority on StreamNow and provides no defense to Aurelius's infringement claims.
Third, and independently, StreamNow's failure to conduct even the most basic due diligence on MDD's claimed authority underscores the absence of any good-faith basis for StreamNow's exploitation of Aurelius's content. StreamNow is a sophisticated content platform with estimated annual revenue of $312 million, backed by $145 million in institutional venture capital, staffed with experienced content acquisition professionals (including VP of Content Acquisition Sandra Yee), and represented by sophisticated outside counsel. Industry practice — and common sense — would have required StreamNow to verify MDD's authority by contacting Aurelius directly. A single phone call or email to Aurelius would have immediately revealed that MDD had no authority to license Aurelius's content. StreamNow's failure to take this elementary step is not a defense; it is evidence of willfulness, or at a minimum, reckless disregard for the rights of the copyright holder.
4. StreamNow Does Not Qualify for DMCA § 512 Safe Harbor. To the extent StreamNow might attempt to invoke the safe harbor provisions of the Digital Millennium Copyright Act, 17 U.S.C. § 512, any such defense would fail.
Section 512 provides a limited safe harbor from monetary liability for certain online service providers that passively host user-generated content and comply with specified notice-and-takedown procedures. The safe harbor was designed for platforms that serve as conduits for or hosts of content uploaded by third-party users, not for commercial enterprises that actively acquire, curate, license, monetize, and sublicense copyrighted content as the core of their business model.
StreamNow is not a passive hosting service. It does not host user-generated content. StreamNow actively curates its content catalog, negotiates and executes content distribution agreements with distributors, ingests content into its platform library pursuant to those agreements, assigns content to subscription and advertising-supported tiers, determines pricing structures, selects geographic availability across fourteen countries, and sublicenses curated content bundles to third-party FAST channel operators. StreamNow exercises pervasive editorial and commercial control over every aspect of its content catalog, from selection to monetization to sub-distribution.
StreamNow's business model as a "super-aggregator" — bundling and sublicensing content to FAST channel operators — is fundamentally different from the user-generated content platforms for which § 512 was designed. See Viacom Int'l, Inc. v. Crowne Albany Partners LLC, Inc., 676 F.3d 19, 38 (2d Cir. 2012) (discussing the contours of § 512 safe harbor); Columbia Pictures Indus., Inc. v. Fung, 710 F.3d 1020, 1040–43 (9th Cir. 2013) (denying safe harbor to defendant who actively participated in and induced infringement). StreamNow is the content distributor, not a neutral intermediary. It falls squarely outside the safe harbor provisions of § 512.
5. The Infringement Is Willful. The facts of this case support a finding that StreamNow's infringement of Aurelius's copyrights was willful, entitling Aurelius to enhanced statutory damages of up to $150,000 per work under 17 U.S.C. § 504(c)(2). Multiple independent facts support this conclusion.
First, StreamNow failed to conduct any reasonable due diligence on MDD's claimed authority to license the 217 Aurelius titles. In the content acquisition industry, it is standard practice for a platform acquiring content from a distributor to verify the distributor's authority by contacting the underlying rights holder. This is especially true for a catalog of the size and prominence of Aurelius's library — a library including globally recognized franchises like "Meridian" and "Iron Compass" — where the identity of the rights holder is well known throughout the industry. StreamNow made no effort to verify MDD's authority with Aurelius.
Second, Franklin Ogilvie's prior employment at Aurelius Media Americas was, or should have been, known to StreamNow through standard content acquisition vetting procedures. Any reasonable investigation into MDD's background — including a basic review of Ogilvie's Westmark Health IT profile, industry databases, or public records — would have revealed his prior employment at AMA and the obvious conflict of interest inherent in a former employee's company purporting to license his former employer's content catalog.
Third, the sheer scale of the infringement — 217 titles, 1,038 episodes, distributed in 14 countries, sublicensed to four FAST channel operators, generating $38.6 million in attributable revenue over 22 months — demonstrates a sustained and knowing pattern of exploitation. This was not an isolated or inadvertent incident. This was a systematic, large-scale, commercially motivated exploitation of Aurelius's content library.
Fourth, StreamNow is a sophisticated content platform with the resources, expertise, and industry-standard tools necessary to verify rights claims. StreamNow employs a dedicated VP of Content Acquisition (Sandra Yee) and outside counsel (Grantham Roth & Pearce LLP). It had every capacity and every incentive to conduct proper due diligence. Its failure to do so was, at a minimum, reckless, and more likely reflects a deliberate decision to look the other way.
Fifth, and perhaps most damningly, StreamNow continued its unauthorized exploitation of Aurelius's content even after Aurelius raised concerns. On November 3, 2025, Sandra Yee responded to Raj Anantharam's inquiry by claiming the MDD sublicense as authority — but StreamNow took no steps to verify that claim with Aurelius, to suspend distribution pending investigation, or to engage in any further dialogue. StreamNow continued to stream and sublicense the 217 titles without interruption, and has continued to do so to this day. This post-notice continuation of infringement strongly supports a finding of willfulness. See Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848, 857 (9th Cir. 2017).
6. Contributory and Inducement Claims Against MDD and Ogilvie. In addition to StreamNow's direct infringement, MDD and Franklin Ogilvie are liable for contributory infringement and inducement of infringement.
Contributory copyright infringement occurs where a party, "with knowledge of the infringing activity, induces, causes, or materially contributes to the infringing conduct of another." Metro-Goldwyn-Mayer Studios Inc. v. Grokster, Ltd., 545 U.S. 913, 930 (2005); Perfect 10, Inc. v. Hollowell & Co., 508 F.3d 1146, 1171 (9th Cir. 2007). MDD and Ogilvie materially contributed to StreamNow's infringement by purporting to license content that MDD had no right to distribute and by supplying StreamNow with the digital copies of the works necessary to effectuate the infringement.
Inducement liability arises where a party distributes a device or, by analogy, provides content "with the object of promoting its use to infringe copyright, as shown by clear expression or other affirmative steps taken to foster infringement." Grokster, 545 U.S. at 936–37. MDD and Ogilvie did not merely facilitate StreamNow's infringement; they actively induced it by entering into the MDD-StreamNow Agreement, representing that MDD held distribution rights it did not possess, and providing StreamNow with the content necessary to carry out the infringement.
Ogilvie's conduct was knowing and deliberate. As a former AMA employee, Ogilvie was intimately familiar with Aurelius's content library. He knew that MDD had no authority to license Aurelius's content. He formed MDD shortly after his departure from AMA — a departure prompted by an investigation into his unauthorized access to Aurelius's systems — and proceeded to misrepresent MDD's rights in direct contravention of his separation agreement, which explicitly prohibited the use of any Aurelius intellectual property. Kowalski Decl. ¶ 14; Exhibit B. Ogilvie's conduct represents the most egregious form of copyright infringement: the knowing exploitation of a former employer's content library for personal financial gain.
B. Aurelius Will Suffer Irreparable Harm Absent Injunctive Relief
The irreparable harm to Aurelius from the continued unauthorized exploitation of its copyrighted works is manifest, ongoing, and compounding with each passing day. The Ninth Circuit has consistently held that a copyright holder's loss of control over its copyrighted works constitutes irreparable harm per se. Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d at 865–66; A&M Records, Inc. v. Napster, Inc., 239 F.3d at 1029. As the Ninth Circuit has explained, "the very nature of copyright infringement is that it causes irreparable injury because it undermines the right holder's control over the work." Camberwell & Co. v. Psystar Corp., 658 F.3d 1150, 1162 (9th Cir. 2011).
The infringement here is not historical or completed — it is ongoing. Every day, StreamNow continues to stream the 217 Aurelius works to its subscribers in fourteen countries. Every day, StreamNow's sublicensees continue to make Aurelius content available on their FAST channels. Every day, Aurelius's exclusive rights are violated anew. Every day, the harm compounds. The specific and concrete irreparable injuries to Aurelius include, but are not limited to, the following:
Loss of Licensing Value. The unauthorized availability of Aurelius content on StreamNow's platform, at price points and under commercial terms over which Aurelius has no control, demonstrably reduces Aurelius's licensing leverage with its authorized platform partners. The presence of the same content on an unauthorized and uncontrolled channel directly undermines Aurelius's ability to negotiate exclusive or premium-tier licensing deals, which constitute the economic foundation of its distribution business. Authorized licensees who have paid fair market value for Aurelius content — or who are in active negotiations for such content — are harmed by the knowledge that the same content is simultaneously available through unauthorized channels at unknown and potentially lower prices. This erosion of licensing leverage is a quintessential form of irreparable harm in the content industry, and it cannot be remedied after the fact by a monetary award. Kowalski Decl. ¶¶ 30–33.
Market Displacement. StreamNow's exploitation of Aurelius content in fourteen countries directly competes with and displaces Aurelius's authorized licensees in those same markets. When a consumer watches an Aurelius title on StreamNow, that consumer is — in many cases — a consumer who would otherwise have accessed the same title through an authorized channel. The resulting displacement of viewership from authorized to unauthorized channels reduces the value of Aurelius's authorized licensing deals and diminishes the revenue and engagement metrics that authorized licensees rely upon to justify their licensing fees. This competitive displacement is occurring in real time and cannot be reversed.
Reputational Harm. Aurelius's content is being distributed through a platform and through FAST channels over which Aurelius has no quality control, no editorial oversight, and no ability to manage its brand. Aurelius has invested decades in building and protecting its reputation as a premium content provider. The uncontrolled distribution of its works through unauthorized channels — where the presentation quality, advertising adjacency, and user experience may not meet Aurelius's standards — damages Aurelius's carefully cultivated brand and reputation. This form of harm is inherently difficult to quantify and cannot be adequately compensated through monetary damages.
Ongoing Revenue Loss. Each day of continued infringement adds to the $38.6 million in attributable revenue already generated by StreamNow from the unauthorized exploitation of Aurelius's content. The financial harm to Aurelius is not static; it grows with each passing day, as StreamNow continues to derive subscription revenue, advertising revenue, and sublicensing fees from content it has no right to exploit. While Aurelius will ultimately seek to recover these revenues as damages, the ongoing accrual of additional financial harm during the pendency of this litigation underscores the need for immediate injunctive relief.
Downstream Proliferation. StreamNow has sublicensed Aurelius content to four third-party FAST channel operators — Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — further multiplying the scope of the unauthorized distribution. Each additional sublicensee represents an additional point of distribution, an additional audience exposed to unauthorized copies, and an additional entity that must be brought into compliance. The proliferation of unauthorized copies through downstream sublicensing makes future enforcement more difficult, more expensive, and more time-consuming. The longer the infringement continues, the more deeply embedded Aurelius's content becomes in StreamNow's sublicensing ecosystem, and the more difficult it becomes to restore the status quo ante.
Monetary damages cannot adequately compensate Aurelius for the ongoing erosion of its exclusive rights, its licensing relationships, its content value, and its market position. The harm is not hypothetical. It is not speculative. It has been occurring for twenty-two months and it continues daily. The Court should not permit this state of affairs to persist.
C. The Balance of Equities Favors Aurelius
The balance of equities tips decisively in Aurelius's favor. On one side of the scale is the rightful owner of 217 copyrighted audiovisual works, which has never authorized their distribution through StreamNow or MDD, and which is suffering ongoing, compounding, irreparable harm to its exclusive rights, its licensing program, and its content value. On the other side is a commercial enterprise that has been distributing content it does not own and never validly licensed, generating $38.6 million in revenue from that unauthorized distribution.
An injunction would merely require StreamNow to stop doing what it had no right to do in the first place — distributing Aurelius's copyrighted content without authorization. This is not a case where the requested relief would force a defendant to surrender lawfully acquired rights or dismantle a legitimate business. StreamNow may continue to operate its streaming platform with the content it has lawfully licensed from other sources. The only content it would be required to remove is content it has no right to possess or distribute.
StreamNow's claimed reliance on the MDD-StreamNow Agreement does not create any equitable entitlement to continue infringing Aurelius's copyrights. StreamNow bears full responsibility for its failure to verify the source and validity of its purported rights. As a sophisticated commercial platform with access to experienced content acquisition professionals and outside counsel, StreamNow was in a position to conduct elementary due diligence. Its failure to do so does not generate equitable rights that could outweigh Aurelius's property interests. See Warner Bros. Entm't Inc. v. WTV Sys., Inc., 824 F. Supp. 2d 1003, 1012–13 (C.D. Cal. 2011) (balance of equities favors copyright holder where defendant's claimed reliance on purported license does not outweigh copyright holder's exclusive rights).
StreamNow will suffer no cognizable harm from being ordered to cease the unauthorized use of another party's property. There is no legally cognizable interest in continuing to infringe. Any interim economic burden on StreamNow — such as the loss of subscription and advertising revenue attributable to Aurelius titles — is entirely self-inflicted, resulting from StreamNow's decision to acquire and distribute content without proper authorization from the actual rights holder. StreamNow cannot be heard to complain that an injunction would deprive it of revenue it was never entitled to earn.
Against this, Aurelius faces continuing, compounding harm to its exclusive rights, its licensing program, its content value, and its relationships with authorized distribution partners with each passing day that the infringement continues. The equities overwhelmingly favor the entry of immediate injunctive relief.
D. An Injunction Serves the Public Interest
The public interest strongly favors the entry of injunctive relief in this case. The Copyright Act reflects a fundamental public policy determination — enshrined in the Copyright Clause of the United States Constitution, U.S. Const. art. I, § 8, cl. 8 — that creators and rights holders are entitled to control the distribution of their works. This constitutional and statutory framework is designed to "promote the Progress of Science and useful Arts" by providing creators with the exclusive rights necessary to incentivize the creation and dissemination of original works.
The enforcement of copyright serves the public interest in multiple, reinforcing ways. It incentivizes the creation of new works by ensuring that creators and rights holders can capture the economic value of their creative output. It protects the integrity and functioning of content markets by ensuring that content is distributed through authorized channels under agreed-upon terms. And it ensures fair competition by preventing unauthorized distributors from free-riding on the creative investments of others.
Permitting the ongoing unauthorized distribution of Aurelius's content would undermine the very licensing ecosystem that funds the creation of new film and television content — content that ultimately benefits the public. If sophisticated platforms like StreamNow can distribute content with impunity based on fraudulent licenses from unauthorized distributors, the economic incentives that drive content creation are eroded. The public has no interest in the continued availability of unlawfully distributed content through unauthorized channels; the public interest is served by ensuring that content reaches consumers through authorized, legitimate distribution channels.
Congress specifically authorized injunctive relief in copyright cases, providing in 17 U.S.C. § 502(a) that courts may "grant temporary and final injunctions on such terms as it may deem reasonable to prevent or restrain infringement of a copyright." This statutory authorization reflects Congress's considered judgment that the public interest is served by the prompt cessation of infringing activity. See Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d at 867–68 ("The public has a compelling interest in protecting copyright owners' marketable rights to their work and the authors' right to protect the integrity of the work." (citation omitted)).
The public interest factor weighs strongly in favor of injunctive relief.
VI. PLAINTIFFS ARE PREPARED TO POST AN APPROPRIATE BOND
Pursuant to Federal Rule of Civil Procedure 65(c), Plaintiffs are prepared to post a bond or other security in an amount the Court deems appropriate to compensate Defendants for any costs and damages they may sustain if the Court later determines that the injunction was wrongfully issued.
Given the overwhelming strength of Aurelius's ownership claims — substantiated by valid copyright registrations for all 217 works, an unbroken chain of title confirmed by independent analysis, and the complete absence of any colorable license or authorization — and given the total absence of any legitimate defense to the infringement claims, Plaintiffs respectfully submit that only a nominal bond is warranted. The risk that the injunction will ultimately be determined to have been wrongfully issued is vanishingly small. StreamNow has no valid license, no colorable safe harbor defense, and no basis in law or equity for its continued exploitation of Aurelius's content. MDD and Ogilvie had no authority whatsoever to license the works at issue.
Plaintiffs nonetheless stand ready to post whatever bond the Court may require in the exercise of its sound discretion.
VII. CONCLUSION AND PRAYER FOR RELIEF
For all of the foregoing reasons, Plaintiffs Aurelius Global Media Group PLC and Aurelius Media Americas, Inc. have demonstrated: (1) a strong likelihood of success on the merits of their claims for copyright infringement, contributory infringement, and inducement of infringement; (2) a likelihood of irreparable harm in the absence of preliminary relief, given the ongoing and compounding nature of the infringement; (3) that the balance of equities tips sharply in their favor, as an injunction would merely require Defendants to cease conduct they had no right to engage in; and (4) that the entry of an injunction serves the public interest in the enforcement of copyright law, the integrity of content markets, and the incentivization of creative expression.
WHEREFORE, Plaintiffs respectfully pray that this Court enter the following relief:
1. A temporary restraining order, effective immediately upon entry, requiring StreamNow Holdings, Inc. to cease all reproduction, distribution, and public performance of the 217 audiovisual works owned by Aurelius and identified in Exhibit A to the Complaint filed concurrently herewith;
2. A temporary restraining order requiring StreamNow Holdings, Inc. to remove all Aurelius content from the StreamNow platform and to direct all sublicensees — including Brindoval Channel Networks, Inc., BrightLoop Media, LLC, Velvet Stream Partners, LP, and Pacific Lantern Digital Pty Ltd — to remove all Aurelius content from their respective platforms within forty-eight (48) hours of service of the order;
3. A temporary restraining order requiring Meridian Digital Distributors, LLC and Franklin Ogilvie to immediately cease all purported licensing, sublicensing, or distribution of any audiovisual work owned by Aurelius Global Media Group PLC or Aurelius Media Americas, Inc.;
4. A preliminary injunction, following a hearing to be set by this Court, continuing the foregoing relief through the pendency of this action; and
5. Such other and further relief as the Court deems just and proper.
VIII. DECLARATIONS IN SUPPORT
The following declarations are filed concurrently herewith in support of this Motion and are incorporated herein by reference:
Declaration of Lena Kowalski
Ms. Kowalski serves as Head of Digital Rights Enforcement for Aurelius Global Media Group PLC. In her declaration, filed concurrently as a separate document, Ms. Kowalski attests to, among other things: her discovery of the infringement on October 15, 2025, during a routine audit of unauthorized digital distribution; her escalation of the matter to General Counsel Fiona Hartwell on October 22, 2025; the results of the internal investigation confirming that Aurelius never authorized MDD, StreamNow, or any other entity to distribute the works at issue; the scope of the infringement, encompassing 217 titles — including the "Meridian," "Iron Compass," and "Thornfield" franchises — consisting of 142 feature films and 75 television series comprising 1,038 episodes; the terms of Franklin Ogilvie's separation agreement, including its prohibition on the use of Aurelius intellectual property; and the ongoing and irreparable harm to Aurelius's licensing program, content value, and market position resulting from the continued unauthorized distribution.
Declaration of Dr. Nathan Frey
Dr. Frey serves as Director of Digital Media Forensics at CipherTrace Analytics, LLC, located at 2700 Sand Hill Road, Suite 130, Menlo Park, California 94025. In his declaration, filed concurrently as a separate document, Dr. Frey attests to, among other things: his professional qualifications and expertise in digital media forensics; the methodology employed by CipherTrace, including content fingerprinting technology and metadata extraction protocols; CipherTrace's confirmation that all 217 Aurelius titles are present and being actively streamed on the StreamNow platform; CipherTrace's verification that the works on StreamNow are identical digital copies of the Aurelius originals; CipherTrace's view