The following commentary comes from an independent investor or market observer as part of TheStreet's guest contributor program, which is separate from the company's news coverage.

NEW YORK (

TheStreet

) -- Speculation that activist investor Carl Icahn has taken a stake in

Research in Motion

(RIMM)

caused shares to jump on Wednesday.

If true, Icahn could push for a board seat and press the company to consider a sale. RIM continues to struggle in the smartphone and tablet market due to increasing competitive pressures from

Apple

(AAPL) - Get Report

and Samsung, and as a result, shareholders are increasingly frustrated with management and expecting major changes.

Our

$26 price estimate for RIM stock

is about 15% above the market price.

Earlier this month, another activist shareholder Jaguar Financial Corp. urged RIM to

consider

a sale of the company or a sale of its patents in order to maximize shareholder value. Now, if the report on Icahn buying a stake in RIM is true, the pressure on RIM to make radical changes would increase.

Icahn made a similar move on Motorola by pushing for a board seat in the company, pressuring the company to split into two. The company split into

Motorola Mobility

(MMI) - Get Report

and

Motorola Solutions

(MSI) - Get Report

in January this year. He then urged the company to consider splitting off its patent portfolio in order to cash in on surging interest in wireless technology. Eventually, Motorola Mobility agreed to sell itself to

Google

(GOOG) - Get Report

last month for a valuation of $12.5 billion.

Despite increasing pressure, we believe shareholders face many difficulties, and it will not be easy for them to achieve the desired result. Firstly, management's willingness to consider a sale will be one of the most important factors as the two co-CEOs of RIM own 11% of the company shares.

Secondly, a lack of a strategic fit for potential buyers and a comparatively weaker patent portfolio are some of the other hindrances that shareholders might face, something we discussed in an

earlier article

.

Regarding the patent portfolio, investors were disappointed last week when Jefferies suggested to clients that RIM's wireless patents have a maximum liquidation value of only about $2.5 billion, or $1 billion if it continues to make smartphones.

See our complete analysis for RIM stock

here

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This commentary comes from an independent investor or market observer as part of TheStreet guest contributor program. The views expressed are those of the author and do not necessarily represent the views of TheStreet or its management.