FACTS: Qimonda AG, a German corporation that manufactured semiconductor devices and random access memory (RAM), filed for insolvency in Munich, Germany, in January 2009. Its principal assets consisted of some 10,000 patents, about 4,000 of which were U.S. patents. These patents were subject to cross-license agreements with Qimonda's competitors, as was common in the semiconductor industry to avoid infringement risks caused by the "patent thicket" resulting from the overlapping patent rights of some 420,000 patents in the semiconductor industry.