It's exactly like a "protection tax" that small guys have to pay. After the small guys pay, they go to the big ones and show them the list of complying companies as "proof" that they are right. It's a typical patent troll strategy.

But Samsung is a big company. They should join B&N and Motorola and go to court with Microsoft. This will get others to do the same. It works both way. The more of Microsoft's patents get invalidated, the better for them in the long run anyway, because not only will Microsoft double the price next time, but others will start looking through their patent database and see if they can use anything to get a license fee from Android manufacturers as well.