The above mentioned cases, if extended to Standard Essential Patents, can bind the patentee into honoring his FRAND commitments based on which the prospective licensee had started manufacturing products. The patentee made a general promise to grant a license to everyone willing to pay a reasonable royalty and based on that promise, the licensee started production. Later,refusal by the patentee to provide a license cannot be a ground for injunction as he must be estopped from refusing to provide a licence.