to stop piracy, as by this point the Nagravision 1 system had been thoroughly reverse-engineered by resourceful hobbyists, an incompatible Nagravision 2 encryption system was introduced along with a smart card swap-out for existing customers. As more cards were swapped, channel groups were slowly converted to the new encryption system, starting with pay-per-view and HDTV channels, followed by the premium movie channels. This effort culminated in a complete shutdown of the Nagravision 1 datastream for all major channels in September, 2005. Despite these efforts to secure their programming, a software hack was released in late August, 2005, allowing for the decryption of the new Nagravision 2 channels with a DVB-S card and a PC. Just a few months later, early revisions of the Nagravision 2 cards had been themselves compromised. Broadcast programming currently uses a simulcrypt of Nagravision 2 and Nagravision 3, a first step toward a possible future shutdown of Nagravision 2 systems. Litigation Various groups have been targeted for lawsuits in connection with pirate decryption issues: In 2006, a decision in Snow v. DirecTV preserved the right of a private website owner to prohibit DirecTV from accessing an otherwise-public website run by plaintiff Michael Snow to serve anti-DirecTV activists. DirecTV (as the euphemistically-named "End Users Group") had engaged in widespread litigation against its own subscribers on the pretext that users who owned both a smartcard programmer and a DirecTV subscription were presumed to be using the equipment to unlock extra channels on the system. A hundred thousand users were harassed with repeated and legally-questionable demands seeking thousands of dollars per user. In 2004's DirecTV v. Treworgy, the Electronic Frontier Foundation helped establish that DirecTV cannot sue individuals for "mere possession" of smart-card technology, forcing the company to drop its "guilt-by-purchase" litigation strategy. "NagraStar" (a joint venture of Nagravision/Kudelski and DishNetwork/Echostar) has also targeted US end users with legal threats and demands for money. EchoStar, as parent of Dish Network, has sued manufacturers of FTA receivers, claiming that the manufacturers were aware of or complicit in the distribution of aftermarket software which unlocks channels transmitted with compromised encryption schemes. The company has also sued operators of websites which published information about the security issues. DirecTV has used the Digital Millennium Copyright Act and the Federal Communications Act to target developers and distributors of software that allowed users to hack DirecTV's older generation access cards. One 2006 settlement in US