Previously we discussed a Unified Patents’ article, the “FRAND SCAM” fails to address many key points. But worse than these sins of omission, the article goes so far as to make some outlandish misrepresentations about the overturned TCL decision. For example, Unified incorrectly posits that the “court […] concluded […] that Ericsson had violated its FRAND obligations.” However, the TCL decision actually determined that Ericsson had met its FRAND obligations with respect to its course of conduct. The decision states: “Ericsson negotiated in good faith and its conduct during the course of negotiations did not violate its FRAND obligation.” (p3) The article also incorrectly claims that Ericsson agreed with TCL on the number of patents that were actually essential. However, as the TCL decision makes clear, “Ericsson made numerous challenges to the process that produced these numbers […]. Ericsson challenged the results of this process…” (p30) Ericsson challenged these numbers because TCL’s “experts” spent only 20 minutes per patent in their analysis, producing a vast over-counting of industry’s essential patents to Ericsson’s detriment. Indeed, this was the exact criticism that the UK court leveled on this type of exercise. Tellingly, a later study found the results of the 20-minute-per-patent review to be comparable to random guesswork.