From Faegre & Benson Legal site.

<In addition, although the defendant won in this case, the Supreme Court opinion suggests that parties can limit the scope of patent exhaustion by including specific licensing terms. However, the patent owner must include those terms in the license agreement—which may be more difficult in light of this ruling. >

I assume they are not reffering to difficulty in coming up with proper language and they are suggesting that the first tier licensees will now balk at having restrictions placed in the license agreements. Perhaps those first tier licensees will see those restrictions as coming back to hurt them if their customers do not obtain licenses. But if there is no restrictive language, they will be paying more, at least they should be. Not sure what the difficulty is. Comments welcomed. Opty