The Federal Circuit, 2-1, affirmed an order holding EchoStar in contempt for violating a permanent injunction.  The injunction issued after TiVo won a patent infringement case against EchoStar.  The majority agreed with the district court that EchoStar's post-judgment redesign efforts didn't go far enough.  TiVo, Inc. v. EchoStar Corp., No. 09-1374 (Fed. Cir. Mar. 4, 2010).