Patent retaliation emerged in response to proliferation and abuse of software patents. Dayton has been the home for many patents and inventions since the 1870s. VPX has several patents and proprietary trademarks. Many such compression techniques may be subject to legal claims relating to software patents. They found that these Qualcomm microchips infringe patents owned by Broadcom. Alice countersued CLS Bank for infringement of the patents. Recommender systems have been the focus of several granted patents. Bose has a reputation for being particularly protective of its patents, trademarks, and brands. Langer holds over 1,350 granted or pending patents. Both companies agreed to cross-license microprocessor patents. Polaroid asked for $12 billion for infringements of its patents by Kodak. Shockley was granted over ninety US patents. In 1978 the total patents granted was 30. He obtained a law degree and registered several patents. Harry obtained radio companies, foreign sound patents and a lithograph company.