Had come across this thread after experiencing no dolbly digital when playing netflix movie/tv shows thru atv gen. 3. It was not until after I had read mcgratpc's post, that I was able to come to a proper solution to my problem (which in my case was not a problem as a result of something apple or netflix did or did not do, but was a result of setup error on my part. My solution: Given that a title in netflix is offered and in fact shows in its apple tv listing that it is encoded with dolby processing by having the accompanying dolby symbol along with the title info, I proceeded as follows: 1) I made sure that the apple tv was selected as speaker in the airplay setting; 2) made sure that sound check, sound effects, and dolby digital were set to on and that the audio output was set to auto in the audio/video settings; 3) I connected my apple tv to my old marantz receiver with the hdmi and toslink connections. 4) I then found a movie that showed the dolby symbol in its title info. I turned on my receiver, pressed play on the atv remote and selected the hdmi input; I then selected the toslink input. In both instances the dolby digital symbol appeared on my receiver display and all seven speakers (5.2) were doing their thing ....NICE!!! This is what I learned: No downgrading or upgrading of firmware was necessary; setup error, such as in my case, not having sound check and sound effect on in the a/v setup menu resulted in no dolby output for me even though I always had dolby digital set to on; and even though sound check may not need to be on, when I took this que from mcgratpc' post and did what he did, and it worked, nothing else mattered; and last but not least, the title listed in the netflix package offered on atv must show the dolby symbol in the title info somewhere, and if not, there will not be any dolby signal to be had, period.
It took 29 pages to get here, but thank you so much mcgratpc for your most helpful info.