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A few years ago, the Children's Hospital of Philadelphia and the AIDS Healthcare Foundation were accused of patent infringement.'Their alleged wrongdoing? Purchasing routers and using them to provide wireless services. 2 A small Atlanta-based company called BlueWave, along with hundreds to thousands of small businesses, received demands for royalties for patent infringement. 3 The accusation? Using an off-the-shelf PDF machine. 4 Recently, the City of Raleigh, the Massachusetts Bay Transportation Authority, and hundreds of cities, transit agencies, and other entities were sued for patent infringement. The offense? Implementing vehicle tracking technology that enabled real time transit arrival information. 5