Xuan-Thao Nguyen (SMU) & Jeffrey A. Maine (Maine) have published Acquiring Innovation, 57 Am. U. L. Rev. 775 (2008).  Here is the Conclusion:

A robust innovation acquisition market fosters desirable innovation development at the lower strata, comprised mostly of small entities and research universities. Accordingly, it is important to have sound tax rules that encourage acquisitions of innovation for societal good and, at the same time, achieve important tax policy goals such as efficiency and administrability. There are several ways in which to incentivize desirable acquisitions. Tax breaks are currently offered to inventors and other transferors of innovation. Adequate economic tax incentives also could be offered to innovation purchasers to achieve optimal innovation outcomes and enhanced economic growth. Any incentives, however, should not apply to acquisitions of innovation for offensive use purposes, because they would only serve to hinder further innovation.