Business to business commerce is fundamentally different than consumer commerce. If you buy something as a consumer, it is reasonable to expect that all licensing etc is taken care of, and there are laws to protect you from liability (plus it would be prohibitively expensive to go after all the individual consumers rather than the manufacturer). But business to business, they can contract how they want when it comes to patents that only cover specific uses of a product, not the manufactured product itself. There is no collusion to avoid patents, Qualcomm merely states in their contract that the purchase of their part does not include third party patent licenses that may be required for certain usage of the product. It is then up to Samsung to do their homework and find out what patents they need to license. They may also offer patent indemnification at a higher part price, but for a large company like Samsung with its own staff of patent lawyers, and its own patents that can be cross licensed, it will almost always be cheaper to handle the licensing themselves.