The tentative decision, released Wednesday, strengthens Nokia's position as it negotiates with Qualcomm over the rights to use Qualcomm's technology for advanced, third-generation phones. Those talks broke off earlier this year.
Qualcomm Chief Executive Officer Paul Jacobs said at the time the deal collapsed that both sides were both so far apart it would take some kind of legal determination to rejuvenate the talks.
"I hope Paul is right," Nokia Chief Financial Officer Rick Simonson said Wednesday during a conference call to discuss the decision.
Qualcomm filed a complaint against Nokia with the International Trade Commission in June 2006. The company said Wednesday it intends to petition the commission for review of Judge Paul J. Luckern's initial determination. A final ruling by the commission is scheduled to be issued by April 14.
The decision addresses just one of 11 lawsuits or complaints now under review in which Nokia and Qualcomm contend patent violations. Qualcomm said the action Wednesday does not address the most important of these legal battles, which is over Qualcomm's WCDMA or "3G" products.