TiVo

(TIVO) - Get Report

won a patent case against

EchoStar

(SATS) - Get Report

, but the 47% stock rise Wednesday may reflect a far too bullish scenario.

A federal court shot down EchoStar's argument that it had created a successful solution that works around TiVo's DVR technology. In the decision, the court awarded TiVo $103 million, which is on top of the $105 million payment that EchoStar parent

Dish Network

(DISH) - Get Report

made to TiVo a year ago.

Barclays Capital analysts wrote Wednesday that they expect Dish to settle with TiVo, taking about 3 cents from the company's bottom line this year and another 9 cents per share next year.

But analysts who have followed TiVo and Dish for some time say it may be too early to expect a settlement and that Dish, which has already said it plans to appeal, will drag the patent dispute out much longer. Also, the dramatic stock price jump implies that the ruling against Dish would apply to all set-top DVR makers like

Cisco's

(CSCO) - Get Report

Scientific-Atlanta and

Motorola

( MOT).

TiVo's DVR technology is "fundamentally different" from the approach Scientific Atlanta and Motorola have been working with for two years," says independent industry analyst Brian Coyne.

It would be wrong to assume that TiVo will now try to apply this ruling to all DVR makers. If anything, TiVo isn't out to make enemies with everyone, says Coyne.

TiVo made a splash in 2000 when DirecTV offered its set-top DVR boxes that allowed TV viewers to record and replay programs as well as skip commercials. Those features became common on competing boxes and were offered as DVR services by cable, phone and satellite shops.

And while Dish fought TiVo's patent claims, other players like

Cablevision

(CVC)

sought different methods of recording and playback. Cablevision successfully argued last year that its network-based DVR system was the same as a home DVR. The network-based approach doesn't seem to have an obvious TiVo conflict. Cablevision is expected to introduce the service this summer.

While TiVo's Dish award, if it stands, is a handsome prize for the company's past achievements, it doesn't address TiVo's present challenges as a standalone DVR maker in a highly competitive market, says Coyne.

And the limits of the ruling and the prospect of more court battles certainly doesn't put as much faith in TiVo as the 47% stock jump would imply.