Icahn could also try to finagle one or more seats on Apple's board, a tactic he has used in the past in other board battles for influence and control.
While that may seem a long shot by some, companies have buckled to the same kind of pressure Icahn can apply. In August, for example, Microsoft announced an agreement with ValueAct Capital, an activist shareholder that had pressed for changes in Redmond for much of the year.
Under the terms of the deal, Microsoft gave ValueAct's president the option of joining the company's board in early 2014. As of Sept. 30, ValueAct owned 66.7 million shares of Microsoft, or approximately 0.8 percent of the total. At Friday's closing price, ValueAct's holdings were worth about $2.5 billion.
By comparison, Icahn's 4.7 million shares represented 0.5 percent of Apple's outstanding shares, and were worth $2.6 billion at Friday's closing bell.
One analyst has long believed that Icahn would not go quietly into the night. In interviews since August, Patrick Moorhead, principal analyst of Moor Insights & Strategy, has called the Icahn-Apple saga a story "that will keep on giving," and pegged the activist's interest in Apple as "absolute trouble" for the company in the mid- and long-term.
Gregg Keizer covers Microsoft, security issues, Apple, Web browsers and general technology breaking news for Computerworld. Follow Gregg on Twitter at @gkeizer, or subscribe to Gregg's RSS feed . His email address is firstname.lastname@example.org.
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