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The article mentions "actually using the patent" as being a criteria - having a history of having people voluntarily pay you for your IP seems to be pretty clear cut evidence of "actually using the patent".

The bigger loop-hole, it seems, is the exemption of "technology transfer organizations". What is the difference between a legitimate such, and a shell patent troll? They both have the explicit purpose of holding an inactive patent for the purpose of commercialising it.



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