In a decision that may increase competition in the cell phone industry, a federal appeals court says a patent holder can be sued under antitrust laws for deceptive conduct toward an organization that sets uniform telecommunications standards.

The ruling, issued Tuesday by the 3rd U.S. Circuit Court of Appeals in Broadcom Corp. v. Qualcomm Inc., No. 06-492, is the first to address the issue and reverses a lower court holding that dismissed the antitrust claims.