Item 8.01. Other Events.

On September 4, 2009, DISH Network Corporation ("DISH Network") issued a press release regarding a ruling by the U.S. District Court in EchoStar Communications Corporation vs. Tivo. In partially granting Tivo's motion for contempt sanctions, the District Court awarded $2.25 per DVR subscriber per month for the period from April 2008 to July 2009 (as compared to the award for supplemental damages for the prior period from September 2006 to April 2008, which was based on an assumed $1.25 per DVR subscriber per month). By the District Court's estimation, the total award for the period April 2008 to July 2009 is approximately $200 million (the enforcement of the award has been stayed by the District Court pending DISH Network's appeal of the underlying June 2009 contempt order). As previously disclosed, we increased our reserve for the Tivo litigation to reflect both the supplemental damages award for the period September 2006 to April 2008 and for the estimated cost of alleged software infringement for the period from April 2008 through June 2009. In the preparation of our financial statements for the three months ending September 30, 2009, we intend to review our total reserve in light of the court's most recent ruling. A copy of the press release is filed as Exhibit 99.1 to this Form 8-K and is incorporated by reference herein.