Elliptic curve was a minefield of patents when Sun Microsystems carefully crafted the OpenSSL implementation to avoid any patent infringement. The resulting source code was vetted by their attorneys.
If any of those patents are still in force, then a naive implementation could infringe.
"Sun Microsystems has donated ECC code to OpenSSL and the Network Security Services (NSS) library..."
https://lwn.net/Articles/174784/
https://en.m.wikipedia.org/wiki/ECC_patents
A lot more attention was likely paid to this code than to heartbleed.