Avoiding willfull infringement no longer requires paying off a
patent attorney to get a freedom to operate review.  This isn't to say
that reading patents is always productive

That case raised the bar a bit, but the core problem remains - if you learn about a patent you definitely violate (and there is very likely to be at least one and possibly many), via whatever means, then by continuing business you become a wilful violator. Which makes sense: how could it be any other way?

It still never makes sense to read patents. You can only lose.