This might be some new information.
My friend has been having this problem for a while. He's sending it in to Apple to get it replaced, and in the meanwhile he's borrowing mine. Mine has never had the problem at all in all of my usage of it. However within a couple of days of him using it at his place, my Apple TV just recently experienced the issue.
So perhaps it has something to do with the environment in which the aTV is in, either the remote controlling it or the TV it's connected to via HDMI. Again, my aTV never had the issue and only just experienced it when it was transferred to his place temporarily, so there must be some kind of event triggering it to happen. If it helps, his TV is a Sony X850C. The aTV is connected to the internet via ethernet to an Airport Time Capsule, though so was mine so that might not be the issue. The TV could be doing something funky over the HDMI interface causing the bug to trigger on the tvOS, or maybe something on the network could be doing it.
Hopefully this information adds to the discussion.