Broadcom has filed a new patent claim in the Southern District of California arguing that Qualcomm has improperly required customers who purchase chipsets for use in cell phone handsets to pay additional licensing fees when the handsets are sold. In Quanta Computer v. LG Electronics, 128 S. Ct. 2109 (2008), the U.S. Supreme Court recently held that a patent holder may not restrict the use of an invention after it sells that invention to a customer. Where the patent owner sells components that substantially embodied the patented invention, even if they are combined with other components, the Court held that the sale exhausts the patent. Broadcom argues that similar reasoning should render Qualcomm’s patents exhausted.