Looks like Dish may have spoken a bit too soon.
A little over a week ago,that Dish Network (formerly EchoStar Communications) had indeed violated a software patent held by TiVo on digital video recorders.
While TiVo gleefully celebrated, Dish expressed disappointment, but assured its customers that none of its products would be affected because the software that was in violation had already been remotely updated by the company some months before.
Now it appears there's just a bit more to the story. Engadget has a blog pointing to notices Dish sent on Monday. The Colorado-based satellite TV company informed customers that though most of its DVRs are in the clear, there are four models--the 721, 921, 942, and Homezone 1022--that can no longer be sold because their software has not been updated. This only affects hardware bearing those model numbers that have not been sold or activated. If you already have one of those models installed, Dish says it is not subject to the injunction.
It's really important to note that these are fairly old models, so this likely won't affect many Dish resellers. The 942 model, for example, was.