I think probably the exact same thing, if the resulting VM was not a spec-compliant VM or otherwise did not fall under the various IP exemptions. Dalvik itself is a much bigger opening for someone to use software patents in a predatory way - if what Gosling's been saying lately is true, Oracle had that as a goal all along. But much of that has to do with the unique peculiarities of Dalvik - a VM that runs something that's like, but isn't quite Java-as-specified.