TiVoNomo officially downgrades SATS from HOLD to SHORT SELL.

Citing valuation concerns and ill advised run-up after Citigroup upgrade.

TiVo litigation may not directly be a liability for SATS, but any substantial loss to parent company DISH will cause SATS to face losses as well.

Why? DISH and SATS are both majority owned by Mr Charlie Ergen. There is opportunity to play a shell game if DISH is in a position where they must raise capital. They can also lower costs by cutting margins at SATS. Dish is THE major customer for SATS. Also, lost customers due to higher DVR fees due to TiVo litigation will harm SATS as well.

I would hesitate to buy SATS anywhere near these levels until TiVo litigation is resolved or SATS inks a major deal.

Target price $12.