XiDrone Systems Inc v. Ondas Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: XiDrone Systems, Inc. (Florida)
  • Defendant: Ondas Inc. and Ondas Autonomous Systems Inc. (Nevada)
  • Plaintiff's Counsel: Bayramoglu Law Offices LLC
• Case Identification: 2:26-cv-01116, D. Nev., 04/10/2026
• Venue Allegations: Venue is asserted in the District of Nevada on the basis that both Defendants are Nevada corporations.
• Core Dispute: Plaintiff alleges that Defendants' counter-unmanned aerial systems (CUAS) and associated components infringe seven U.S. patents related to the detection, tracking, identification, and mitigation of drone threats.
• Technical Context: The technology lies in the counter-drone security domain, a field focused on protecting critical infrastructure, public venues, and sensitive airspace from the risks posed by small unmanned aerial systems.
• Key Procedural History: The complaint references a prior case, XiDrone Systems, Inc. v. 911 Security Inc., in which the U.S. District Court for the Northern District of Texas determined that similar XiDrone patent claims directed to "actively tak[ing] action to suppress the threat" were not abstract and were patent-eligible under 35 U.S.C. § 101. The complaint also details pre-suit communications, including written notices and infringement claim charts provided to Ondas beginning on December 12, 2025, which form the basis for allegations of willful infringement.

Case Timeline

Date	Event
2014-12-19	Earliest Priority Date for all Patents-in-Suit
2019-05-07	U.S. Patent No. 10,281,570 Issued
2020-06-02	U.S. Patent No. 10,670,696 Issued
2020-10-06	U.S. Patent No. 10,795,010 Issued
2022-07-05	U.S. Patent No. 11,378,651 Issued
2022-09-27	N.D. Texas court ruling in XiDrone v. 911 Security
2023-05-09	U.S. Patent No. 11,644,535 Issued
2024-09-17	U.S. Patent No. 12,092,756 Issued
2025-05-13	U.S. Patent No. 12,298,378 Issued
2025-12-12	XiDrone provides written notice of patent portfolio to Ondas
2026-01-06	XiDrone provides claim chart for '756 Patent to Ondas
2026-04-07	XiDrone provides notice and claim charts for six other patents-in-suit
2026-04-10	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,281,570 - "Systems And Methods For Detecting, Tracking And Identifying Small Unmanned Systems Such As Drones"

• Patent Identification: U.S. Patent No. 10,281,570, titled "Systems And Methods For Detecting, Tracking And Identifying Small Unmanned Systems Such As Drones," issued May 7, 2019 Compl. ¶23

The Invention Explained

• Problem Addressed: The patent addresses the challenge of countering small, commercially available unmanned aerial systems (sUAS) in civilian environments (Compl. ¶40, citing '756 Patent, col. 1:40-67). It notes that traditional military air defense systems are ill-suited for this task, as they are designed for larger, faster targets and often employ kinetic or electronic countermeasures (e.g., GPS jamming) that pose a high risk of collateral damage in populated areas (Compl. ¶¶41-43, Compl. ¶citing '756 Patent, Compl. ¶¶col. 3:9-51).
• The Patented Solution: The patent proposes an integrated system that uses multiple sensor types to detect, locate, and interdict a drone ʼ570 Patent, abstract The system specifically uses radio frequency (RF) detection to identify a drone's communication signal, compares the signal to a library to identify the drone type, and then defines and transmits a tailored electronic countermeasure (ECM) to disrupt its operation in a non-destructive manner ʼ570 Patent, abstract ʼ570 Patent, col. 9:44-55
• Technical Importance: The invention describes a multi-layered, non-lethal approach for civilian counter-drone security, shifting from military-style kinetic engagement to a more precise, signal-based interdiction method Compl. ¶45

Key Claims at a Glance

• The complaint asserts independent claim 20 and dependent claims 21 and 22 Compl. ¶165
• The essential elements of independent claim 20 include a computer-readable medium with instructions to cause one or more processors to perform the actions of:
  • detecting a radio frequency (RF) signal employed for communication between a remote controller and a drone;
  • determining a direction of the drone;
  • comparing signal characteristics of the RF signal with a library;
  • defining an electronic countermeasure (ECM) based on the comparison; and
  • transmitting the ECM to interdict the drone.
• The complaint reserves the right to assert additional claims Compl. ¶166

U.S. Patent No. 10,670,696 - "Drone Threat Assessment"

• Patent Identification: U.S. Patent No. 10,670,696, titled "Drone Threat Assessment," issued June 2, 2020 Compl. ¶25

The Invention Explained

• Problem Addressed: Beyond simple detection, security systems need a way to assess the level of threat a drone poses to determine an appropriate response '696 Patent, col. 2:4-11 Prior art military systems lacked a nuanced threat assessment framework suitable for civilian contexts, where responses must be proportional and minimize collateral damage '696 Patent, col. 3:3-50
• The Patented Solution: The invention discloses a system that detects a vehicle via radio transmissions, creates a unique identifier for it, and performs a "threat assessment" using the collected data '696 Patent, abstract As detailed in the specification, this assessment may involve a "Threat Assessment (ThA)" process that generates a "threat value (ThV)" based on multiple criteria such as location, classification, speed, and flight profile, allowing the system to trigger a proportional response '696 Patent, Fig. 6 '696 Patent, col. 21:30-48
• Technical Importance: This technology provides a systematic framework for evaluating drone behavior to determine intent and risk, enabling an automated or human-in-the-loop decision on whether and how to mitigate a potential threat Compl. ¶47

Key Claims at a Glance

• The complaint asserts independent claim 2 and dependent claims 3, 6, 8, 10, 11, 14, and 16 Compl. ¶230
• The essential elements of independent claim 2 include a system configured to:
  • scan a radio frequency spectrum;
  • detect a vehicle by receiving radio transmissions involving the vehicle, wherein the radio transmissions include data sent from the vehicle;
  • create a unique identifier for the vehicle using at least a portion of the data; and
  • perform a threat assessment for the vehicle using at least a portion of the data.
• The complaint reserves the right to assert additional claims Compl. ¶231

Multi-Patent Capsules

• U.S. Patent No. 10,795,010: "Systems And Methods For Detecting, Tracking And Identifying Small Unmanned Systems Such As Drones," issued October 6, 2020 Compl. ¶27

  • Technology Synopsis: This patent describes a system using at least one RF receiver and at least one radar to detect a target drone. A processor identifies the target based on its RF signature, locates it using radar data, and determines if it is a UAS, after which an electronic countermeasure (ECM) can be deployed to disrupt its communications Compl. ¶¶326-365
  • Asserted Claims: Independent claims 6 and 7 are asserted Compl. ¶323
  • Accused Features: The accused features include Ondas' integrated system combining SentryCS RF receivers and Iron Drone Radar to detect and identify targets, along with its ECM capabilities for drone mitigation Compl. ¶¶326, 332, 340, 365

• U.S. Patent No. 11,378,651: "Deterrent For Unmanned Aerial Systems," issued July 5, 2022 Compl. ¶29

  • Technology Synopsis: This patent discloses a system combining a range sensor (e.g., radar) and a directional/omnidirectional sensor (e.g., RF) to detect and locate a target drone. Upon detection, the system dispatches its own "counter unmanned aerial vehicle" that is guided by an RF control signal to intercept the target based on autonomous navigation data supplied by the system Compl. ¶¶409-437
  • Asserted Claims: Independent claim 1 and several dependent claims are asserted Compl. ¶406
  • Accused Features: The allegations map to Ondas' system using radar and RF sensors to detect a threat, which then dispatches the "Iron Drone Raider" interceptor drone to neutralize it Compl. ¶¶409, 415, 430, 437

• U.S. Patent No. 11,644,535: "Deterrent For Unmanned Aerial Systems," issued May 9, 2023 Compl. ¶31

  • Technology Synopsis: This patent describes a method for interdicting an aerial target by receiving its RF signals to determine a signature, using sensors to find its direction and range, and then dispatching a counter-drone to intercept the target while both are airborne. The system transmits an RF control signal to guide the counter-drone toward the target based on navigation data Compl. ¶¶476-515
  • Asserted Claims: Independent claim 1 and several dependent claims are asserted Compl. ¶473
  • Accused Features: The allegations are directed at Ondas' system using RF and radar sensors to locate a target and then dispatching and guiding the Iron Drone Raider interceptor via RF signals Compl. ¶¶476, 482, 502, 508, 515

• U.S. Patent No. 12,092,756: "Deterrent For Unmanned Aerial Systems," issued September 17, 2024 Compl. ¶33

  • Technology Synopsis: This patent claims a system wherein one or more processors coupled to at least one radar determine the direction and range of a drone target. Based on this determination, the processors dispatch a counter unmanned aerial vehicle via a transmitted RF signal to interdict the target Compl. ¶¶554-562
  • Asserted Claims: Independent claim 11 and several dependent claims are asserted Compl. ¶551
  • Accused Features: The allegations target the Ondas Iron Drone Raider System, which uses radar to determine a target's location and processors to dispatch the Raider interceptor via an RF signal Compl. ¶¶554, 557, 562

• U.S. Patent No. 12,298,378: "Counter Unmanned Aerial System With Navigation Data To Intercept And/Or Disable An Unmanned Aerial Vehicle Threat," issued May 13, 2025 Compl. ¶35

  • Technology Synopsis: This patent claims a system using multiple ground-based sensors, including radar and an image sensor, connected to a processor. The processor determines if a UAS is a threat based on its proximity to a protected area and, if so, counters it by dispatching a counter-drone with autonomous navigation data supplied by the system Compl. ¶¶604, 613, 621
  • Asserted Claims: Independent claim 1 is asserted Compl. ¶601
  • Accused Features: The allegations concern the Ondas system's use of Iron Drone Radar and "Insight" optical sensors to determine if a drone is a threat to a perimeter, followed by the dispatch of the Iron Drone Raider to counter it Compl. ¶¶604, 609, 621

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Ondas' "Multi Layered Defense" system, also marketed as "One Autonomous Domain" Compl. ¶¶78-79

Functionality and Market Context

• The complaint describes the accused product as an integrated counter-unmanned aerial system (CUAS) composed of several key technologies Compl. ¶79 These include the "Iron Drone Radar" for detection, "Sentry CS" for RF-based detection and "cyber" or "soft" mitigation, and the "Iron Drone Raider," an interceptor drone that provides a "hard mitigation" capability, often by deploying a net to capture a target Compl. ¶¶79, 85, 92-93 A screenshot from a marketing video depicts the system architecture, showing the "IRONDRONE RADAR," "INSIGHT" optical sensor, and "SENTRYCS" RF sensor as distinct components of the integrated system Compl. p. 19 The complaint alleges this system is marketed for protecting critical infrastructure, defense sites, and public venues, and has been sold to government and enterprise customers Compl. ¶¶89, 94, 96

IV. Analysis of Infringement Allegations

10,281,570 Infringement Allegations

Claim Element (from Independent Claim 20)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
detecting an radio frequency (RF) signal employed for communication between a remote controller and a drone;	The Ondas system's RF technology detects drones by intercepting and analyzing radio transmissions and signal bursts characteristic of drone datalinks.	¶174; ¶175	col. 9:44-47
determining a direction of the drone;	The system determines the directional vector to a drone by using the drone's transmitted latitude and longitude in relation to the known locations of the system's sensors.	¶178	col. 10:1-3
comparing signal characteristics of the RF signal with a library;	The system's "Cyber Over RF (CoRF)" technology analyzes signal content and compares it to a library of specific drone vendors, models, and remote controls.	¶181; ¶183	col. 10:5-9
defining an electronic countermeasure (ECM) based on the comparison;	Based on the library comparison, the system defines the appropriate ECM to deploy against the identified drone.	¶185	col. 10:9-12
transmitting the ECM to interdict the drone.	The system transmits the defined ECM to perform interdiction, with alleged outcomes including "Threat Mitigated By Cyber," disconnecting the drone from its remote control, or taking it over. A marketing video screenshot shows this outcome Compl. p. 22	¶188; ¶191	col. 10:13-16

• Identified Points of Contention:
  • Scope Questions: A potential point of contention may be the claim term "defining an electronic countermeasure." The analysis will question whether the accused system's alleged selection of a pre-programmed countermeasure from a library based on drone type meets the claim's requirement to "define" an ECM, which could be construed as creating or generating the countermeasure parameters in real-time.
  • Technical Questions: The complaint alleges the system determines "direction" using the drone's lat/long coordinates relative to sensor positions Compl. ¶178 This raises the question of what evidence supports that this functionality relies on the "RF signal" as the basis for the directional determination, as required by the claim's structure, rather than a separate GPS data stream or other sensor input.

10,670,696 Infringement Allegations

Claim Element (from Independent Claim 2)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
scan a radio frequency spectrum;	The accused system can be configured by operators to "scan specific frequency bands" to detect drone activity.	¶236; ¶238	col. 13:20-22
detect a vehicle by receiving radio transmissions involving the vehicle, wherein the radio transmissions include data sent from the vehicle;	The system's RF technology detects transmitting drones and analyzes signal bursts containing datalinks, which inherently include data from the vehicle.	¶239; ¶240	col. 13:23-26
create a unique identifier for the vehicle using at least a portion of the data;	The system generates and displays unique identifiers for detected drones, such as "Drone 104...DJI Mavic 2 P[ro]," based on the data received.	¶242; ¶243	col. 13:27-29
perform a threat assessment for the vehicle using at least a portion of the data.	The system performs "Threat Classification" based on drone data, assessing whether a drone is "Unauthorized" or "Approaching" a protected perimeter. A marketing video screenshot explicitly shows the "Threat Classification" function Compl. p. 20	¶249; ¶250; ¶251; ¶255	col. 13:30-32

• Identified Points of Contention:
  • Scope Questions: The analysis may focus on whether displaying a system-assigned label (e.g., "Drone 131") constitutes "creat[ing] a unique identifier for the vehicle using at least a portion of the data." A dispute could arise over whether this is creating an identifier from the data itself or merely assigning a label to a detected object.
  • Technical Questions: A key question will be what evidence the complaint provides to directly link the "data sent from the vehicle" (e.g., drone type, serial number) to the "threat assessment" (e.g., its status as "approaching"). The infringement theory depends on showing that the assessment uses the data from the transmission, not just independently derived location or movement data.

V. Key Claim Terms for Construction

From U.S. Patent No. 10,281,570

• The Term: "defining an electronic countermeasure (ECM) based on the comparison"
• Context and Importance: This term is critical as it describes the transition from passive detection to active interdiction. The case may turn on whether Ondas' system, which allegedly selects a countermeasure from a library, performs an act of "defining." Practitioners may focus on this term because it distinguishes between merely picking a pre-set tool and creating a tailored solution.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes determining the "most appropriate RF signal characteristics to affect the subject sUAS" ʼ570 Patent, col. 9:49-51 This language could support a construction where selecting the "most appropriate" characteristics from a list constitutes "defining" the ECM for that specific encounter.
  • Evidence for a Narrower Interpretation: The word "defining" may suggest creating, calculating, or generating the ECM parameters, not just selecting them. The patent's reference to a "signal generator [that] produces a tailored signal" ʼ570 Patent, col. 12:12-13 could be cited to support a narrower construction requiring real-time parameter generation.

From U.S. Patent No. 10,670,696

• The Term: "threat assessment"
• Context and Importance: The scope of "threat assessment" is central to the '696 patent. Its construction will determine the level of analytical sophistication required to infringe. The dispute may center on whether a simple rule (e.g., a drone crossing a boundary is a threat) is sufficient, or if a more complex, multi-factor analysis is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires only "perform[ing] a threat assessment... using at least a portion of the data" '696 Patent, cl. 2 This could be interpreted to encompass any process that evaluates data to determine if a threat exists.
  • Evidence for a Narrower Interpretation: The specification details a "Threat Assessment (ThA)" process that calculates a "threat value (ThV)" from multiple criteria (location, classification, speed, payload, size, flight profile) '696 Patent, col. 21:30-67 '696 Patent, Fig. 6 A party could argue that to "perform a threat assessment" as taught by the patent, a system must perform this type of quantitative, multi-factor analysis.

VI. Other Allegations

• Indirect Infringement: The complaint alleges Ondas induced infringement by encouraging and instructing customers, such as the NYPD and organizers of the FIFA World Cup, to use the accused "Multi Layered Defense" system in an infringing manner Compl. ¶¶214-216 Compl. ¶¶307-309 It also alleges contributory infringement, stating that Ondas provides technology that is a material part of the patented inventions, is especially designed for infringing use, and is not a staple item of commerce Compl. ¶¶221, 314
• Willful Infringement: The complaint alleges willful infringement based on Ondas' alleged pre-suit knowledge of the patents-in-suit. This knowledge is purportedly established through a series of written notices and detailed infringement claim charts that XiDrone sent to Ondas beginning on December 12, 2025, and continuing through April 7, 2026 Compl. ¶¶137, 141, 152-153 The complaint further alleges that Ondas has a policy of not reviewing the patents of others, which it characterizes as willful blindness Compl. ¶157

VII. Analyst's Conclusion: Key Questions for the Case

• A foundational issue, which the plaintiff has proactively raised, will be patent eligibility: can the claims, which recite processing sensor data and initiating countermeasures, withstand a challenge under 35 U.S.C. § 101 as being directed to an abstract idea? The plaintiff's citation to a favorable ruling on this issue in prior litigation suggests this will be a central and early battleground.
• A core infringement dispute will be one of definitional scope: for the RF-interdiction claims, does the accused system's alleged act of selecting a pre-programmed countermeasure from a library constitute "defining" an electronic countermeasure as required by the claims, or is there a critical distinction between selection and definition that absolves the defendant of infringement?
• A key evidentiary question will be one of functional equivalence: does the accused system's "Threat Classification" function perform the quantitative, multi-factor "threat assessment" detailed in the '696 patent's specification, or is there a fundamental mismatch in technical operation between the product's rule-based alerts and the patent's more sophisticated analytical process?