One of the justifications of motion for reconsideration is new evidence, period. You don’t need anything else. The whole reconsideration process will determine if such new evidence is indeed valid and if so whether such new evidence would have altered the outcome of the existing order. So in front of the judge, he has two piles of code printouts, each weighs about 50 lbs, one from the previous submittal during the trial, one just hauled in by DISH with fresh Kinko’s scent. They most definitely will look, read and word differently because they are two different codes. Here you have it, a new evidence, compared to the old pile which was used as evidence back then, and that is all that’s needed to justify the motion for reconsideration. Again I am not say this is what DISH will ask for, but this is how they will get the motion for reconsideration if they want to. You have posted it yourself how it is done, why argue with your own research results?