Federal Judge Lucy Koh overseeing two Apple versus Samsung smartphone patent suits has issued her first ruling after the December 6 omnibus post-trial hearing. In her first ruling, the judge has declined to adjudicate Apple's fair, reasonable, and non-discriminatory (FRAND) defenses against Samsung's patent claims, citing that the jury didn't find Apple infringing, so there was no need to rule on the asserted standards-essential patents held by the Korean manufacturer.