I would argue that its actually pro-consumer - because if I was Google's CEO, I would just shut down AOSP, and wish that I had done it years ago, in relation to this ruling.
Google supports AOSP and has done so for years, making it available freely. Why shouldn't they be able to dictate their own terms? If phone makers don't like it, they can make their own OS (which they have - and they all suck).