DeviceGuru writes "A hypervisor can be used to isolate from each other software works released under incompatible licenses, while allowing them to run simultaneously on the same hardware. For example, Linux and Windows CE can run on separate virtual machines on one device, without violating either OS's license. Due to the isolation between multiple VMs running atop a hypervisor, it seems like this architecture could allow companies to build Linux-based devices, such as mobile phones or set-top boxes (think TiVo), that can't be upgraded by their users without authorization, thereby circumventing the GPLv3's 'anti-tivoization' clauses."
Here's a white paper with more details
from a commercial hypervisor company.