Complaint for Patent Infringement Against Hextronics, LLC. Filing Fees $ 405.00 Receipt Number AFLSDC-19363839, Filed by Asylon, Inc.. (Attachments: # 1 Civil Cover Sheet, # 2 Summon (s), # 3 Exhibit a -- U.S. Patent No. 12,030,403, # 4 Exhibit B -- U.S. Patent No. 11,318,859, # 5 Exhibit C -- Asylon Presentation to Hextronics, # 6 Exhibit D -- Hextronics Universal Quick Start Guide 2024, # 7 Exhibit E -- '403 Patent Assignment, # 8 Exhibit F -- '859 Patent Assignment, # 9 Exhibit G -- January 23, 2024 Letter to Hextronics, # 10 Exhibit H -- January 31, 2024 Email from Hextronics, # 11 Exhibit I -- January 23, 2024 Email to Hextronics, # 12 Exhibit J -- August 18, 2025 Letter to Hextronics, # 13 Exhibit K -- September 25, 2025 Letter from Hextronics, # 14 Exhibit L -- November 21, 2025 Email to Hextronics, # 15 Exhibit M -- January 12, 2026 Email to Hextronics)(Allerding, John)

Document #1 Filed 03/27/2026 · 43 pages · District Court, S.D. Florida · View original PDF

1Asylon, Inc. (“Plaintiff” or “Asylon”) is a corporate entity that conducts business under the trade name, Asylon Robotics. Asylon is a corporation established and existing under the laws of the State of Delaware, with its principal place of business at 52 Buttonwood Street, Norristown, Pennsylvania, 19401, United States.

2On information and belief, Defendant Hextronics, LLC (“Defendant” or “Hextronics”) is a limited liability company established and existing under the laws of the State of Florida, with its principal place of business at 12194 128th Street, Miami, Florida, 33186, United States.

JURISDICTION AND VENUE

3This is an action for patent infringement under the United States Patent Laws, 35 U.S.C. § 1 et seq., specifically including 35 U.S.C. § 271.

4This Court has subject matter jurisdiction in this matter pursuant to 28 U.S.C. § 1331 and § 1338(a) and 35 U.S.C. § 281 because this action arises under the patent laws of the United States.

5This Court has personal jurisdiction over Hextronics because Hextronics has its regular and established principal place of business in, and has committed acts of infringement in, this judicial district.

6Venue is proper in the Southern District of Florida pursuant to 28 U.S.C. § 1391(b), (c) and 28 U.S.C. § 1400(b).

FACTS AND PATENTS IN SUIT

7This action for patent infringement arises out of Defendant’s infringement of Plaintiff’s U.S. Patent No. 12,030,403 (Ex. A), and U.S. Patent No. 11,318,859 (Ex. B) (collectively, the “Asserted Patents”). Plaintiff brings this action to compel Defendant to compensate Plaintiff for its infringement of the Asserted Patents and to cease its ongoing and continuous infringement of the Asserted Patents.

8On July 9, 2024, the U.S. Patent and Trademark Office duly and legally issued U.S. Patent No. 12,030,403 (the “’403 Patent”) entitled “Methods for Reconfigurable Power Exchange for Multiple UAV Types” to Asylon. It names Damon C. Henry, Adam I. Mohamed, Brent McLaughlin, and David Dones as inventors.

9As of the filing of this action, Asylon is the owner of all right, title, and interest in the ’403 Patent by virtue of a written assignment from the inventors listed above, recorded with the USPTO Assignment Recordation Branch on April 4, 2022, sufficient to confer standing (Ex. E). The ’403 Patent lists Asylon as assignee.

10The ’403 Patent is generally directed towards a method for swapping a power supply in an unmanned aerial vehicle (“UAV”) through utilization of a reconfigurable power station (“RPS”). The RPS autonomously exchanges modular “swap cartridges” to extend the flight range and mission capability of the UAV. The RPS includes a dynamic terminal landing system with markers that generate scalable composite images to guide autonomous landing of the UAV onto the RPS, a swapping mechanism positioned on a vertical elevator system that first removes the depleted cartridge from the UAV and subsequently obtains a second swap cartridge from the receiving bays within the RPS, and then transfers that second swap cartridge into the housing of the UAV. Afterwards, the RPS transmits a clearance signal for takeoff to the UAV once a pre-flight check of the UAV is complete.

11On May 3, 2022, the U.S. Patent and Trademark Office duly and legally issued U.S. Patent No. No.11,318,859 (the “’859 Patent”) entitled “Methods for Reconfigurable Power Exchange for Multiple UAV Types” to Asylon. It names Damon C. Henry, Adam I. Mohamed, Brent McLaughlin, and David Dones as inventors.

12As of the filing of this action, Asylon is the owner of all right, title, and interest in the ’859 Patent by virtue of a written assignment from the inventors listed above, recorded with the USPTO Assignment Recordation Branch on April 2, 2018, sufficient to confer standing (Ex. F). The ’859 Patent lists Asylon as assignee.

13The ’859 Patent also discloses a method of swapping out and replacing a power supply cartridge in a UAV through utilizing an RPS system. The RPS is comprised of a dynamic terminal landing system with visible or non-visible markers that transmit signals to a UAV when it is in proximity to the landing zone located on the RPS. After the UAV has landed, the RPS determines the orientation of the UAV relative to the landing zone. The RPS then removes the first swap cartridge on the UAV utilizing a swapping adaptor located on a vertical elevator system from within the RPS. The RPS obtains a second swap cartridge from the receiving bays within the RPS, which are in fixed positions and aligned symmetrically relative to one another. The RPS installs the second swap cartridge into the housing on the UAV and then transmits a clearance signal for takeoff to the UAV once a pre-flight check on the UAV is complete.

14In accordance with 35 U.S.C. § 282, the ’403 patent and ’859 Patent are each presumed valid.

15On January 23, 2024, Asylon sent a detailed notice letter to Hextronics’ leadership identifying Asylon’s patent portfolio and enclosing a copy of the ’859 Patent.1 The letter explained that Hextronics’ “Universal CS” product and related technologies appeared to be covered by the claims of the Asserted Patents (Ex. G).

16On January 31, 2024, Hextronics promptly acknowledged that it had received the notice letter and attachments and requested a claim chart “outlining which claims” Asylon believed Hextronics was incorporating (Ex. H).

17At the time of the initial notice, the letter specifically identified and attached the ’859 Patent and referenced Asylon’s published applications. Upon information and belief, Hextronics was on notice of Asylon’s patented and published claims and of potential enhanced damages for willful infringement at least as early as the date the notice letter was first sent on January 23, 2024, and at least as late as when Hextronics confirmed receipt of the notice letter in its responsive letter to Asylon, on January 31, 2024.

18Following a period of time, on August 18, 2025, Asylon sent another notice letter to Hextronics expressly directing Hextronics’ attention to the two Asserted Patents, the ’859 Patent (claims 1 and 11) and the ’403 patent (claims 1 and 11), and enclosed both patents in the letter as 1 On January 24, 2024, Asylon transmitted the same notice letter by email to Hextronics’ executives (Ex. I). well for Hextronics’ reference. Asylon invited Hextronics to discuss the identified claims in detail, also transmitting the August 18, 2025 letter by email to Hextronics on the same day (Ex. J).

19On September 25, 2025, Hextronics acknowledged receipt of the notice letter and sent a written response contending non-infringement based on its asserted operational differences, such as use of a “moving landing pad in which the aircraft lands within and then brought into the station.” (Ex. K).

20On October 9, 2025, the parties met for a claims-focused meeting where Asylon leadership presented and walked through its claim interpretations and positions of infringement with Hextronics, highlighting the similarities between Asylon’s patented technology and the Hextronics device. Asylon outlined these theories of infringement in presentation slides, attached hereto as Exhibit C.

21Following this meeting and Asylon’s presentation, on October 27, 2025, Asylon followed up in good faith with Hextronics’ CEO, Curt Larry, “to see if [Hextronics] wanted to move forward and discuss terms for a potential licensing deal.” (Ex. L). Asylon has followed up with Hextronics regarding this proposition by email on multiple occasions following the meeting (including on November 21, 2025, December 5, 2025, and January 12, 2026), but there have been no further communications received from Hextronics related to this matter (Ex. M).

22The claim charts below in Paragraph 24 are the same charts presented to Hextronics on October 9, 2025, and show how at least independent claims 1 and 11 of the ’859 Patent read on Hextronics’ “Universal CS” product or “drone-in-a-box” system (“Accused Product”), based on information currently available to Asylon and its attorneys. These claim charts are not meant to limit the scope of Asylon’s infringement claim in any way and are intended to be without prejudice to Asylon’s ability to assert different or additional claims of the ’859 Patent against Hextronics

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