33. Defendants’ Visionsat receivers are designed to utilize a new form of satellite
piracy known as Internet Key Sharing (“IKS”), also called Control Word Sharing. Defendants
and their pirate end-users use a satellite dish to intercept DISH Network’s encrypted satellite
transmission that is intended for legitimate and authorized DISH Network customers.
34. Once Defendants’ Visionsat receiver intercepts DISH Network’s encrypted
satellite transmission it locates a special part of the satellite transmission known as the encrypted
Entitlement Control Message and sends that encrypted Entitlement Control Message over the
internet to Defendants’ master computer server (the “IKS Server”) believed to be located in
Korea. Defendants’ IKS-Server responds by providing a decrypted “control word” (“Control
Word”). The IKS Server has the ability to decrypt the Control Word because it is connected to a
legitimate subscribed or “hacked” DISH Network Access Card at the server location that decrypts
the Control Word. The unencrypted Control Word is sent back to the consumer’s Visionsat
receiver. Once the Control Word has been returned to the Visionsat receiver by the IKS Server,
the unencrypted Control Word acts like a key that unscrambles the otherwise-scrambled and
encrypted DISH Network television programming.
35. Visionsat-brand receivers are designed for and do engage in IKS-based piracy and
therefore pose a unique threat for two primary reasons. First, unlike traditional satellite receivers
modified for piracy, which require hackers to generate a “fix” or “update” following an ECM, and
then require hackers or end-users to manually install it onto each satellite receiver affected by an
ECM, these IKS satellite receivers are designed to obtain all the information that they need to
descramble DISH Network Programming (including all “fixes” and “updates”) directly from an
IKS Server via the Internet. These satellite receivers are thereby automatically immune to ECMs
and operate continuously to steal DISH Network Programming. Pirates often boast that these
receivers “never go down”. Second, because these satellite receivers rely on the IKS Server, they
are able to descramble DISH Network Programming even after the completion of the transition to
new DISH Network Access Cards. For this reason, these satellite receivers effectively
circumvent the security enhancements found in newer generation DISH Network Access Cards.
36. Visionsat receivers can also operate in an emulation mode, where software is
loaded that assists the receiver in mimicking or emulating a legitimate DISH Network Access
Card instead of control words being downloaded in real-time from the IKS Server.
38. Pirates, including Defendants, also sell and use devices known as “Dongles” that
permit satellite receivers, including Visionsat receivers, to connect to the Internet using a
receiver’s built in RS-232 port and thereby access an IKS Server for piracy purposes. Once a
“Dongle” is connected to an IKS-enabled satellite receiver, the user newc***news.net simply downloads IKS Pirate
Software from various websites, including www.f****.com, installs the Pirate Software, and then
enters the Internet address of the IKS Server. Once complete, the Visionsat receiver, “Dongle”,
and Pirate Software work together to provide the customer unlawful and unlimited access to
DISH Network Programming without authorization from or payment to DISH Network.