I'm guessing Microsoft's Nokia financial support agreement for Windows devices includes stipulations about Nokia not being acquired by Apple
"According to Nokia’s Q1 results for 2012, the vendor estimates that the current annual IPR royalty under its smart phone and mobile devices business unit income run-rate is approximately €0.5 billion.Nokia still has a patent business • The Register
It is unclear how much if these royalties are coming directly from the ongoing spoils of Nokia’s victory with Apple last June, but it would be assumed the lion’s share would be Apple derived."
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