EXHIBIT A

EXHIBIT B

REDACTED

REDACTED

REDACTED
REDACTED

REDACTED

EXHIBIT C

REDACTED

REDACTED

REDACTED

REDACTED

EXHIBIT D

o
O'Melveny & Myers
BEIJING

lep

1999 Avenue of the Stars

Los Angeles, California 90067-6035

BRUSSELS
HONG KONG

TELEPHONE

LONDON

FACSIMILE
LOS ANGELES

(310) 553-67OO
(310) 246-6779

www.omm.com

NEWPORT BEACH

SAN FRANCISCO
SEOUL
SHANGHAI
SILICON VALLEY
SINGAPORE
TOKYO

NEW YORK

WASHINGTON, D.C.

WRITER'S DIRECT DIAL

VIA E-MAIL

(310) 246-6850

September 1, 2016

WRITER'S E-MAIL ADDRESS

dpetrocelli@omm.com

David Hyman
General Counsel
Netflix, Inc.
100 Winchester Circle
Los Gatos, CA 95032

Re:

NOTICE TO CEASE AND DESIST

Dear Mr. Hyman:

We have been retained by Twenty-First Century Fox, Inc. and Fox 21, Inc. (collectively Fox)
regarding Netflixs tortious interference with Foxs employment contracts and its unlawful
solicitation and hiring of Fox employees.
Earlier this year, Netflix induced Marcos Waltenberg, then Vice President, Promotions for Fox,
to breach his written employment contract in order to accept employment with Netflix. Netflix
did so with full knowledge of Mr. Waltenbergs contractual obligations to Fox and over Foxs
express objection.
Fox has recently learned that Netflix has now induced Tara Flynn, Vice President, Creative, to
breach her written employment contract with Fox in order to commence employment with
Netflix. Once again, Netflix did so with full knowledge that Ms. Flynn is under contract to
Fox. Ms. Flynn has notified Fox of her intention to leave Fox Friday, September 2. We have
informed Ms. Flynn that Fox does not consent to her stated departure prior to the expiration of
her contract and that such departure would violate the terms of her written employment contract
with Fox.
Fox hereby demands that Netflix refrain from employing Ms. Flynn in violation of her contract
with Fox. We further notify you that if Netflix proceeds to employ Ms. Flynn prior to the
expiration of her written employment contract, Fox intends to hold Netflix fully accountable for
its wrongful actions. Netflixs tortious actions are part of an unlawful campaign to target and
poach valuable Fox employees and solicit them to break their contracts with Fox to join
Netflix. We demand that Netflix immediately cease and desist from any such further conduct.

OMelvenya Myers
September 1, 2016 - Page 2

llp

Netflixs wrongful solicitation and hiring of Ms. Flynn also threatens Foxs trade secrets. As an
executive in creative affairs, Ms. Flynn has been privy to Foxs valuable trade secret
information. Indeed, Ms. Flynn and her group are currently producing a television show for
Netflix. Fox will take vigorous action to defend any misappropriation of its trade secrets by
Netflix.
Given the seriousness of these issues, Fox hereby notifies Netflix of its obligation to preserve all
documents, data, and tangible things (hereafter Records) in its possession, custody, and control
that are potentially related to this dispute, including all electronically stored information, and not
to destroy, delete, erase or over write any such Records. The scope of preservation should
include, at a minimum, all Records relating to the solicitation, hiring, and employment of Mr.
Waltenberg, Ms. Flynn, and any other current or former employees of Fox.
Fox reserves all rights and remedies, all of which are expressly reserved.
Very truly yours,

Daniel M. Petrocelli
of OMEL YEN Y & MYERS LLP

DMP:jcl