They can recognize revenue if certain conditions are met. It takes delivery of the product ( in this case companies using the patents). Collection must be reasonably assured. The revenue can reasonably be measured ( I believe they stated at least for Samsung they were using a conservative number. I assume they believe Lenovo will pay at least the judgment amount.
I think it more accurately shows the revenue matching to periods than getting lump sums for past sales and recognizing it then (which in those cases, it was when it was reasonably assured).