On August 11, 2020, in FTC v. Qualcomm, the Ninth Circuit reversed the May 21, 2019 decision by Judge Lucy Koh of the U.S. District Court for the Northern District of California, which held that Qualcomm’s patent licensing program was unlawfully anticompetitive, and vacated Judge Koh’s permanent, worldwide injunction that had prohibited several of Qualcomm’s core business practices. The Ninth Circuit held that: (i) Qualcomm did not have an antitrust duty to license its standard-essential patents to rival modem chip manufacturers; (ii) Qualcomm’s patent license royalty rates were not unlawfully anticompetitive; and (iii) Qualcomm’s other alleged conduct, including its “no license, no chips” policy, was not prohibited by the U.S. antitrust laws because it did not undermine competition in a relevant antitrust market.