[ChuckMcM]

This is my understanding as well. Most of the people Microsoft has sued for android patents have had some other part of the business that would go sideways if Microsoft withheld something (usually Windows) from them. B&N had no such weakness and so could see a patent suit all the way to the supreme court if it wanted, and since the Nook wasn't doing great anyway, the only 'downside' for B&N was that the Nook subbusiness went out of business.

So very uneven on the risk/reward equation for Microsoft. They finesse it by "investing" and getting another "licensee" for their patents.