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Taking legal action against *all* companies producing software stacks for smartphones would allow Microsoft to claim with some semblance of plausibility that it was not specifically targeting Linux this time (unlike its previous sabre-rattling statements about patent infringement that were specifically aimed at Linux). But the net effect would be that Linux would be the chief victim of such an approach, since any companies using it in their smartphones are likely to end up doing deals with Microsoft - and hence implicitly accepting its claims - whatever the open source community might think or want. It would be like Novell's pact with Microsoft, writ large and much worse.
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