Microsoft has continued its run of convincing Google's mobile hardware partners to agree to mutually beneficial patent licensing terms in its latest deal with ZTE. With more than 20 Android manufacturers now signing deals with Microsoft, some are wondering if the remaining few will be able to hold out much longer.

The ZTE partnership comes on the heels of a landmark deal reached with Hon Hai earlier in the month, and places another global top-five smartphone manufacturer on terms with Microsoft.

"Much of the current litigation in the so-called 'smartphone patent wars' could be avoided if companies were willing to recognize the value of others' creations in a way that is fair," Microsoft deputy general counsel Horacio Gutierrez explained. "At Microsoft, experience has taught us that respect for intellectual property rights is a two-way street, and we have always been prepared to respect the rights of others just as we seek respect for our right."

According to The Guardian, the stage could be set for negotiations between Microsoft and (the now Google-owned) Android manufacturer Motorola. Although the two sides have a history of disagreement surrounding standards-essential patents, the intellectual assets tied into the Android licensing deals Microsoft has secured with Samsung, Sony, ZTE and others can be commercialized on free market terms.