Unless they don't own any patents in the US for their most great products, it could be the case.
Still RIM has a long experience with secure mobile systems, so that's a good thing to have in your assets. So, the thing is not if RIM is worthy or not for another company to buy. It's about the price and this analyst is playing for someone to spread the word to it's cheaper to buy. Been there, done that.
Wonder how their employees line up is. Do they still have the good old employees that gave birth to the first BB's?
Cheers!