ORM + You = Lawsuit
"FireStar recently filed a lawsuit (also in East Texas) against Red Hat for the use of the principle of Object Relational Mapping in Hibernate (developed by JBoss), a popular component of Java applications. Jim Farmer of immagic has confirmed that Sakai uses Hibernate
and is, therefore, vulnerable to both direct and indirect infringement
charges by FireStar. Farmer has also confirmed that while uPortal 2
does not use Hibernate, plans are underway to incorporate the component
in uPortal 3. FireStar's patent claim goes beyond Hibernate, which is
only one implementation among many of the Object Relational paradigm.
Potentially any web framework that uses ORM, including those deployed
in PHP, Ruby on Rails, or .NET, is vulnerable."
[1] http://tatler.typepad.com/nose/2006/08/the_patent_cris.html