Royalty disputes under patent-license agreements often arise when there are multiple licensed entities in the supply chain.  Resolving such disputes often requires analysis of whether the doctrine of patent exhaustion prevents the patent holder from collecting royalties from the ultimate seller and thus requires royalties be paid by the manufacturer. In a recent decision in MPEG LA, LLC v. Audiovox Electronics Corp., the trial court in Suffolk County, New York, explored this issue and determined that under the contract at issue the ultimate seller was responsible for paying royalties under the parties’ license.