Well, MS is still extorting money from android vendors using os related patents.
If you honestly think Samsung would willingly hand over $10-15 per handset over bunk patents, I've got some oceanfront property in Arizona you might be interested in.
That has nothing to do with Linux or Android directly, and everything to do with ANY CELLPHONE.
These patents aren't being used passively. They are being used for royalties. And Samsung wouldn't pay the royalty unless there was a strong legal case.