If the September 2020 Continental Automotive Systems, Inc. opinion is any indicator, the answer seems to be “yes,” at least where an alleged violation of fair, reasonable, and nondiscriminatory (“FRAND”) terms and conditions is concerned. Following on the heels of F.T.C. v. Qualcomm Inc., the Northern District of Texas dismissed a complaint in which Continental Automotive Systems, Inc. (“Continental”) alleged, among other things, that Nokia Corporation and other technology companies (together, “Licensor Defendants”) violated Sections 1 and 2 of the Sherman Act by pooling their standard essential patents (“SEP”) in joint licensing entities called Avanci, LLC and Avanci Platform International Limited (together, “Avanci”). Continental Auto. Sys., Inc. v. Avanci, LLC