If the Rockstar shareholders can be shown to have direct control over this, the DoJ and FTC may get involved. From this interview/fluff piece: http://www.ip-rockstar.com/Press_Releases/IAM%20Rockstar%20A...

Commitments to the DoJ

The sale of the Nortel patents closed on 29th July 2011, which also happens to be Veschi’s birthday. But it took another few months – until Spring 2012 – for the acquisition to receive clearance from the US Department of Justice (DoJ). Although this approval may have taken some time to obtain, the only commitment that Rockstar itself gave to the DoJ (and the Federal Trade Commission) was that it would operate autonomously. This, explains Veschi, was so that the shareholders “as operating companies cannot pick and choose who we will target”