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Wildcat Licensing v. Parrot Drones — UAV Navigation Patents | PatSnap
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Case ID6:23-cv-00449
FiledJun 2023
ClosedSep 2024
Patent Litigation

Wildcat Licensing v. Parrot Drones: UAV Navigation Patent Dispute Paused at Jurisdiction Stage

Wildcat Licensing LLC asserted three UAV navigation patents against French drone maker Parrot Drones SAS and Parrot S.A. in the Western District of Texas. The court granted Wildcat jurisdictional discovery before any merits ruling, then administratively closed the case — leaving the infringement claims unresolved after 474 days on the docket.

Resolution time
474days
474 days on docket — closed before merits reached, consistent with jurisdictional disputes extending case timelines
Patents asserted
3
US7231294B2, US7228232B2, and US7286913B2 — UAV navigation, obstacle avoidance, and telemetry socket patents
Outcome
Case Dismissed
Case administratively closed; no merits ruling; may be reopened upon party request or court order
Cost ruling
Not Awarded
No costs or fee ruling recorded; case closed before substantive disposition
Published by PatSnap Insights Team · Verified by PatSnap Eureka Data
Case overview

Jurisdictional Fight Stalls UAV Patent Claims Against French Drone Maker

Wildcat Licensing LLC filed suit on June 13, 2023 in the Western District of Texas before Judge Fred Biery, asserting three patents — US7231294B2, US7228232B2, and US7286913B2 — against Parrot Drones SAS and its parent Parrot S.A. The patents cover core UAV navigation functions: general navigation control, obstacle avoidance algorithms, and telemetry data transmission via a socket interface. The accused products are Parrot’s commercial drone lines deployed in the U.S. market.

Rather than reaching infringement merits, the case stalled on personal jurisdiction. Parrot moved to dismiss both Wildcat’s original and first amended complaints, arguing lack of personal jurisdiction over the French entities. On September 29, 2024, the court denied the motion targeting the original complaint as moot given the amended pleading, and simultaneously granted Wildcat’s request for targeted jurisdictional discovery — permitting five interrogatories, seven document requests, and a half-day 30(b)(6) deposition. The case was then administratively closed pending completion of that discovery by November 29, 2024.

The administrative closure — functionally a stay — is notable: 474 days elapsed without any substantive merits ruling. The outcome suggests Parrot’s jurisdictional challenge had sufficient surface credibility to warrant discovery rather than denial outright, yet the court found Wildcat’s stream-of-commerce allegations non-trivial enough to justify testing them. The public record does not disclose whether jurisdictional discovery was completed or whether the case was ultimately reopened, settled, or abandoned after closure.

Case at a glance
Case no.6:23-cv-00449
CourtTexas Western
JudgeFred Biery
FiledJune 13, 2023
ClosedSeptember 29, 2024
Duration474 days
OutcomeCase Dismissed
Verdict causeInfringement Action
BasisCase Dismissed
Prior Art Intelligence
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Case timeline

Filing to Case Dismissed in 474 days

474 days on docket — closed before merits reached, consistent with jurisdictional disputes extending case timelines

Case timeline: Complaint filed JUN 13 2023, FEB–MAR — 474 days total Horizontal timeline showing the three key events in Wildcat Licensing, LLC v Parrot Drones SAS from filing to resolution. Source: PACER, Texas Western District Court. JUN 13 2023 Complaint filed Pre-trial proceedings SEP 29 2024 Case Dismissed 474 DAYS TOTAL
Dismissal terms

Administrative closure explained: what the order means for both parties

Legal mechanism

Administrative closure is a stay, not a final dismissal

An administrative closure removes a case from active dockets without terminating it. The Fifth Circuit has confirmed it functions identically to a stay — the case remains live, parties may still file motions, and the court can reopen it on its own motion or by party request. No merits judgment was entered, and the infringement claims against Parrot Drones SAS and Parrot S.A. remain formally unresolved.

No final judgment on merits
Plaintiff outcome

Wildcat secured discovery rights before any dismissal ruling

The court accepted Wildcat’s argument that its stream-of-commerce allegations were sufficiently specific to justify jurisdictional discovery — a meaningful procedural win. Wildcat retained the right to probe Parrot’s U.S. sales channels, distribution relationships, and knowledge of the Texas market via interrogatories, document requests, and a 30(b)(6) deposition. Whether Wildcat ultimately obtained useful evidence and reopened the case is not reflected in the public record.

Jurisdictional discovery granted
Defendant outcome

Parrot’s dismissal motion remains pending — not yet won

Parrot’s motion to dismiss the First Amended Complaint for lack of personal jurisdiction was not resolved — it was held in abeyance pending jurisdictional discovery. The administrative closure is not a victory on the merits or on jurisdiction. Parrot faces the prospect of the case being reopened once Wildcat completes or concludes discovery, and the personal jurisdiction question remains live and undecided as of the public docket.

Jurisdiction question unresolved
Commercial implications

UAV makers selling into the U.S. face stream-of-commerce jurisdiction risk

The court’s willingness to grant jurisdictional discovery — rather than dismiss outright — signals that foreign UAV manufacturers distributing products through U.S. channels may face personal jurisdiction exposure in Texas even without a domestic subsidiary or direct sales office. Companies in the drone sector that rely on third-party U.S. distributors should assess whether their distribution arrangements create sufficient contacts with Texas to sustain litigation.

Jurisdiction risk for foreign drone OEMs
Legal analysis based on PACER docket records for case 6:23-cv-00449 and PatSnap Eureka litigation intelligence Search PatSnap Eureka ↗
Parties and representation

Full party and counsel information

RoleNameTypeDetail
PlaintiffWildcat Licensing, LLCCompanyPatent licensing entity — holder of US7231294B2, US7228232B2, and US7286913B2Search in Eureka ↗
DefendantParrot Drones SASIndividualFrench commercial drone manufacturer Parrot Drones SAS and parent Parrot S.A.Search in Eureka ↗
Co-DefendantParrot, S.A.IndividualSearch in Eureka ↗
Plaintiff counselAndrew G. DiNovoAttorneyCounsel for Wildcat Licensing, LLCSearch in Eureka ↗
Plaintiff counselChristopher V. GoodpastorAttorneyCounsel for Wildcat Licensing, LLCSearch in Eureka ↗
Plaintiff law firmDiNovo Price LLPLaw FirmRepresenting Wildcat Licensing, LLCSearch in Eureka ↗
Defendant counselB. Russell HortonAttorneyCounsel for Parrot Drones SASSearch in Eureka ↗
Defendant counselJames E. HopenfeldAttorneyCounsel for Parrot Drones SASSearch in Eureka ↗
Defendant counselNeil CaveAttorneyCounsel for Parrot Drones SASSearch in Eureka ↗
Defendant law firmGeorge, Brothers, Kincaid & Horton LLPLaw FirmRepresenting Parrot Drones SASSearch in Eureka ↗
Defendant law firmSinger Cashman LLPLaw FirmRepresenting Parrot Drones SASSearch in Eureka ↗
Presiding judgeJudge Fred BieryJudgeTexas Western District CourtSearch in Eureka ↗
Official verdict

Official order — verbatim text

“Before the Court are: (1) Defendants’ Motion to Dismiss Plaintiff’s Original Complaint (docket #12); (2) Defendants’ Motion to Dismiss Plaintiff’s First Amended Complaint (docket #16); (3) Plaintiff’s Opposed Motion for Jurisdictional Discovery and to Extend Time to Respond to Defendants’ Motion to Dismiss First Amended Complaint (docket #17); (4) Defendants’ Opposition to Plaintiff’s Motion for Jurisdictional Discovery and to Extend Time (docket #18); (5) Plaintiff’s Reply in Support of its Opposed Motion for Jurisdictional Discovery and to Extend Time to Respond to Defendants’ Motion to Dismiss First Amended Complaint (docket #19); and (6) Supplement (Exhibit 1) to Reply in Support of Opposed Motion for Jurisdictional Discovery (docket #20). In the Motion to Dismiss Plaintiff’s Original Complaint, defendants sought dismissal of this case for lack of personal jurisdiction and for failure to state a claim for patent infringement. After the Motion to Dismiss was filed, Plaintiff filed its First Amended Complaint (docket #15). Based on the foregoing, the Court finds the pending motion to dismiss the original complaint should be denied as moot because the First Amended Complaint supersedes the original complaint. Accordingly, based on the filing of the First Amended Complaint (docket #15), the Court finds Defendants’ Motion to Dismiss Plaintiff’s Original Complaint (docket #12) should be denied. Therefore, IT IS HEREBY ORDERED that Defendants’ Motion to Dismiss Plaintiff’s Original Complaint (docket Case 6:23-cv-00449-FB Document 21 Filed 09/29/24 Page 1 of 4 #12) is DENIED AS MOOT in light of the filing of the First Amended Complaint (docket #15). See Meyer v. Shinn Const., PE:18-CV-3-DC-DF, 2018 WL 1905049 at *1 (W.D. Tex. Mar. 3, 2018) (“filing of an amended complaint, which supersedes an original complaint, renders moot a motion to dismissthe original complaint”); Smallwood v. Bank of America, Civil Action No. 3:11-CV-1283-D, 2011 WL 4941044 at *1 (N.D. Tex. Oct. 17, 2011) (granting leave to amend complaint and denying “motion to dismiss without prejudice as moot”); Comb v. Benji’s Special Educ. Acad., Inc., 745 F. Supp. 2d 755, 773 (S.D. Tex. 2010) (denying as moot motion to dismiss “without prejudice to refiling in light of Plaintiffs’ second amended complaint”). With respect to Defendants’ Motion to Dismiss Plaintiff’s First Amended Complaint, Plaintiff has responded by filing its Opposed Motion for Jurisdictional Discovery and to Extend Time to Respond to Defendants’ Motion to Dismiss First Amended Complaint (docket #17). In this motion, Plaintiff Wildcat asserts that “targeted discovery is necessary to test the veracity and completeness of the factual allegations presented in Defendants’ Motion to Dismiss.” Opposed Motion for Jurisdictional Discovery, docket #17 at page 2. Plaintiff maintains that jurisdictional discovery is proper because its First Amended Complaint contains more than just “bare bones jurisdictional allegations, setting forth Defendants’ placing the products in the stream of commerce with full knowledge and foresight they would be sold in Texas” and the United States. Id. at pages 2-3. As a result, Wildcat seeks discovery in the form of (1) five interrogatories; (2) seven document requests; and (3) one half-day 30(b)(6) deposition of a single witness for Defendants. Wildcat also asks that it be allowed to complete this “targeted jurisdictional discovery prior to responding to Defendants’ Motion to Dismiss,” and that its deadline to respond be extended to fourteen days after this targeted discovery is completed. The Court has carefully reviewed and considered the opposed motion, the response, and reply and finds, based on the arguments and authorities presented by the Plaintiff, that the motion has merit and should be granted. -2- Case 6:23-cv-00449-FB Document 21 Filed 09/29/24 Page 2 of 4 Accordingly, IT IS HEREBY ORDERED that Plaintiff’s Opposed Motion for Jurisdictional Discovery and to Extend Time to Respond to Defendants’ Motion to Dismiss First Amended Complaint (docket #17) is GRANTED such that Plaintiff shall be permitted to conduct jurisdictional related discovery, subject to the following limits: 1. Depositions: Plaintiff will be permitted to take one, half-day (4 hours) 30(b)(6) deposition of a single witness for Defendants; and 2. Interrogatories and Document Requests: Plaintiff will be permitted to serve five interrogatories and seven document requests to Defendants. IT IS FURTHER ORDERED that Defendants shall respond to and produce documents in response to Plaintiff’s jurisdictional discovery requests within thirty (30) days of service of the requests, and all jurisdictional-related discovery, including the above-reference deposition, shall be completed on or before November 29, 2024. The jurisdictional-related discovery ordered herein shall not count toward any discovery limitations which may be set by this Court in future orders. IT IS FURTHER ORDERED that the deadline for Plaintiff’s response to Defendants’ Motion to Dismiss Plaintiff’s First Amended Complaint (docket #16) is hereby extended to fourteen (14) days after the completion of jurisdictional-related discovery or no later than December 13, 2024. Defendants shall have fourteen (14) days from the date of the filing of the response to file a reply if they choose to do so. Because this case cannot move forward until the jurisdictional discovery is completed and the response and any reply thereto are filed, the Court finds this case is appropriate for administrative closure. See Mire v. Full Spectrum Lending, Inc., 389 F.3d 163, 167 (5th Cir. 2014) (“District courts frequently make use of this device to remove from their pending cases suits which are temporarily active elsewhere (such as before an arbitration panel) or stayed (such as where a bankruptcy is pending). The effect of an administrative closure is no different from a simple stay . . . .”). -3- Case 6:23-cv-00449-FB Document 21 Filed 09/29/24 Page 3 of 4 Accordingly,ITIS FURTHER ORDERED that theClerk ofCourt ADMINISTRATIVELYCLOSE this case pending further order of the Court. Though administratively closed, this case will still exist on the docket of this Court and may be reopened upon request or on the Court’s own motion. Parties may continue to file motions and documents in the case.”
Source: PACER Docket, Case 6:23-cv-00449, Texas Western District Court

The court’s order does not resolve infringement or validity — it addresses only procedural posture. The denial of the motion to dismiss the original complaint as moot is standard doctrine following an amended pleading. More substantively, the grant of jurisdictional discovery indicates the court found Wildcat’s allegations of stream-of-commerce contact with Texas plausible enough to warrant factual development. The administrative closure, consistent with Fifth Circuit authority in Mire v. Full Spectrum Lending, preserves the case without consuming judicial resources, leaving the personal jurisdiction question — and all infringement claims — formally open.

PACER case 6:23-cv-00449 · Public docket record Explore in Eureka ↗
Patent at issue

US7231294B2, US7228232B2, US7286913B2 — UAV Navigation and Control Patents

Publication No.US7231294B2
Application No.US10/692169
Patent details
ProductUAV navigation and flight control systems
Cited in actionJune 13, 2023

Publication No.US7228232B2
Application No.US11/041831
Patent details
ProductUAV navigation with obstacle avoidance algorithms
Cited in actionJune 13, 2023

Publication No.US7286913B2
Application No.US10/692129
Patent details
ProductUAV telemetry communication via socket interface
Cited in actionJune 13, 2023

The three asserted patents — US7231294B2, US7228232B2, and US7286913B2 — cover distinct but complementary layers of UAV operation. US7231294 addresses foundational UAV navigation and control. US7228232 extends into navigation with obstacle avoidance logic, a capability central to modern autonomous drone operation. US7286913 covers telemetry transmission through a socket interface, relevant to real-time data links between drone and ground station. The application numbers suggest these patents were filed in the mid-2000s, predating the commercial consumer drone market’s expansion.

These patents sit at the intersection of autonomous flight control and data communications — two areas that underpin nearly every commercial and consumer UAV platform sold today. Obstacle avoidance and telemetry are standard features in Parrot’s product lines as well as competitors’ offerings from DJI, Skydio, and others. Wildcat Licensing’s assertion of these patents against a French OEM signals that the licensing entity views this portfolio as having broad applicability across the drone industry, not limited to any single product generation or market segment.

Patent data sourced from USPTO via PatSnap Eureka patent database Search patent records in Eureka ↗
Freedom to operate

Should you run an FTO against US7231294B2, US7228232B2, and US7286913B2?

Any company developing or commercialising UAV platforms with autonomous navigation, obstacle avoidance, or telemetry socket capabilities should treat these three patents as active FTO considerations. The case demonstrates that Wildcat is actively enforcing this portfolio in U.S. courts. Foreign manufacturers selling into the U.S. market via distribution networks are specifically exposed — the Western District of Texas court declined to dismiss on jurisdiction without further factual development.

PatSnap Eureka’s FTO Search Agent can map the claims of US7231294B2, US7228232B2, and US7286913B2 against your drone platform’s navigation stack, obstacle detection modules, and telemetry architecture. Eureka surfaces prior art, identifies design-around opportunities, and flags co-pending continuation risks — enabling R&D and legal teams to make informed product decisions before entering the U.S. market.

PatSnap Eureka FTO Search

Run a freedom-to-operate analysis on US7231294B2 to assess your product’s exposure

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Related litigation

Similar UAV and Drone Patent Infringement Cases in U.S. District Courts

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Strategic implications

What this case signals for the UAV and drone IP landscape

A jurisdictional standoff over UAV navigation patents highlights enforcement risks for foreign drone makers operating in U.S. markets.

Stream-of-commerce pleading can unlock jurisdictional discovery against foreign OEMs

Wildcat’s success in obtaining jurisdictional discovery — despite Parrot’s challenge — suggests that specific allegations about U.S. product distribution can survive early dismissal. Patent licensors targeting foreign drone manufacturers should plead U.S. sales channels, retailer relationships, and market-awareness facts with particularity to reach the discovery phase.

Three UAV navigation patents still in play — no invalidity or non-infringement ruling entered

US7231294B2, US7228232B2, and US7286913B2 have not been adjudicated on validity or infringement. Any drone platform incorporating autonomous navigation, obstacle avoidance, or telemetry socket protocols should treat these patents as live enforcement risks until a final merits ruling or IPR disposition is obtained.

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Frequently asked questions

Wildcat v Parrot — key questions answered

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Map Your Drone Platform Against Wildcat Licensing’s UAV Patent Claims

Three UAV navigation patents remain unadjudicated and enforceable. Use PatSnap Eureka to conduct claim mapping, prior art searches, and FTO analysis across your autonomous flight and telemetry stack before commercial U.S. launch.

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