Among the many reasons high-tech companies get patents, one of the most important is to build a patent arsenal. To guard against the risk of patent litigation, companies acquire patents so they can retaliate against or neutralize threats of suits brought by their competitors. A large patent portfolio is likely to discourage such threats in the first place. As companies seek to outdo their rivals and to minimize the risk of ending up in court, the acquisition of even more patents is justified. Companies seeking freedom to operate have obtained thousands of patents as part of the" patent arms race.,, i. See infra Part IA See generally Stuart JH Graham et al., High Technology Entrepreneurs and the Patent System: Results of the 2oo8 Berkeley Patent Survey, 24 BERKELEY TECH. LJ 1255 (2009)(reporting on surveys that confirm that companies in high-tech industries amass patents as bargaining chips against other patentees and to prevent suits by others); Bronwyn H. Hall & Rosemarie Ham