Two recent decisions clarify and supplement EU case law on the meaning of "fair, reasonable and non-discriminatory" terms in patent licences and provide guidance on how to conclude a FRAND licence and calculate FRAND royalties. This is the first time that an English court has made a FRAND determination and set a FRAND royalty rate. The decisions also signal the dawn of the FRAND defence which may result in a diminishing role for competition law in future FRAND cases.