The news about the complaint against Microsoft (MSFT) for infringement of six of its patents has boosted the sentiment for VirnetX (VHC). The contention is that the infringement falls outside the scope of the previous licensing arrangement with the company. Specific reference is made to Microsoft's Skype products, and VHC seeks both damages and injunction. This news has taken the stock closer to the 50 DMA. At least the sharp fall, which was anyway showing signs of slowing down, has been arrested. In its complaint, VirnetX seeks both damages and injunctive relief. The stock is likely to face resistance at the 50 DMA of $21.93. The good part is that the recent rise has been accompanied by huge volumes. Friday's volume was more than 1.9 million shares compared with the 10 day average of 865K shares and the 3 month average of 1.26 million shares. There was more news from AAPL on the settlement of the lawsuit, and it seems that Apple may be contesting the $368 million claim of VirnetX. The stock which had crashed on news of the adverse judgment in the patent infringement lawsuit against Cisco (CSCO) may face more risk in case the lawsuit is filed. Such fluctuations due to progress in trials points to the need for a diversified business model rather than being a pure patent play. Other companies in the IP business are also understanding the need for a more stable business model with a steady stream of revenues rather than total dependence on monetization lawsuits. For example, Marathon Patents Group (MARA) has recently acquired CyberFone to have a steady stream of revenues from the revenue generating patents of the company. This will give a stable revenue source to Marathon. MARA had recently filed a huge patent infringement lawsuit (through its subsidiary Sampo LLC) against Sony, Dell, Siemens etc. (Markman hearing in October). For VHC, things are not looking too good.