In this specific case there _is_ a direct contract independent of the GPL. The TV came with a notice stating that it used GPL’d software and offering to convey

In this specific case there _is_ a direct contract independent of the GPL. The TV came with a notice stating that it used GPL’d software and offering to convey the source to anyone who wrote them. That’s a valid contract, which the SFC tried to act on. Vizio rebuffed them, so one of the issues before the court is a literal contract violation.