I'll have to try and dig up the filing, but I thought that one comment that Qualcomm made was that their power control mechanism was simply an option for the handset manufacturers. They could choose to use other methods....of course, none of them do so.
Hmmm, so rather than have Qualcomm come up with an alternative method, they could have the individual handset manufacturers attempt to do so. All of the methods might be different which would make BRCM's legal challenges quite a bit more difficult. That would take the legal burden off of Qualcomm....but I'd be pissed if I was a handset vendor.
Slacker