We’ll miss covering the two-year-old infringement battle between Apple and Nokia that settled last week, but by knocking out a major front in the sprawling multi-jurisdictional smartphone patent wars, the deal at least promised to make the whole mess a little easier to follow.

We should be so lucky. Just a day after Nokia agreed to take Apple’s cash and make peace, yet another skirmish broke out. On Wednesday Dolby International’s lawyers at Sullivan & Cromwell sued Research in Motion for allegedly infringing patents that are essential to the BlackBerry’s audio capabilities. The suit may not be on par with the clashes between Apple, Nokia, HTC, Samsung, and Motorola, but it just goes to show that smartphones are going to be the IP litigation bar’s meal ticket for a long time to come.

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