An arbitration to set royalty payments from Samsung could yield a bunch of cash.  From the article:

"Nokia was added to the Top 10 EMEA Ideas List, as its first-quarter catalyst is the Samsung IPR arbitration, where consensus expectations of cE300m p.a./E1.5bn 5yr royalty payment seem conservative. Merrill Lynch also believes that Nokia’s management team may raise Alcatel-Lucent S.A. (NYSE: ALU) deal synergy guidance from €900 million and could increase expected cash returns.

The balance sheet should remain overcapitalized — assuming the Samsung patent arbitration materializes at least inline with our expectations and all ALU convertible debt is converted into equity, we see end-2016 net cash of approximately 10.5 billion euro or 1.8 euro per share. Our 12-month price objective of 9.3 euro implies 44% upside potential. Our scenario analysis over a 18 month to 24 month view of potential deal synergies suggests further upside: should Nokia execute on deal synergies, we believe the market may pay 14 times ex-cash P/E on 2018 EPS in 2017."

Full article:

http://247wallst.com/investing/2016/01/05/why-merrill-lynch-sees-nokia-and-rio-tinto-much-better-in-2016-international-picks-list/