X One, Inc. v. Domino's Pizza, Inc. et al.

Case Overview and Background

Plaintiff X One, Inc. ("X One"), a non-practicing entity (NPE), has filed a patent infringement lawsuit against Domino's Pizza, Inc. and its franchising entity. This case is part of a broader litigation campaign initiated by X One in April 2026, targeting companies with mobile applications featuring location-based tracking and service ordering. X One asserts U.S. Patent No. 9,942,705, which generally relates to a system for exchanging and displaying location information between a mobile device of a service provider and a customer's device. X One has a history of asserting its patent portfolio, which it describes as foundational to the "Global Shared Economy," in prior litigation against companies like Uber.

The technology accused of infringement is the Domino's Pizza mobile application and website, particularly the well-known "Domino's Tracker®" feature. This system allows customers to place orders and then monitor the progress of their order from preparation to delivery, including real-time GPS tracking of the delivery driver. X One alleges that this end-to-end ordering and tracking functionality infringes upon the methods claimed in its '705 patent for creating a temporary network between a user and a service provider to share location data on a map.

The case is filed in the U.S. District Court for the Northern District of California, as specified in the case metadata (4:26-cv-03260). This venue is notable for its experienced judiciary in complex patent matters and local rules that structure the progression of cases, but it is also considered a venue that is statistically more favorable to defendants on early dispositive motions and motions to stay for inter partes review. It is important to note, however, that multiple external litigation databases report this same lawsuit between X One and Domino's as being filed in the U.S. District Court for the Eastern District of Texas under case number 2:26-cv-00311. This discrepancy is significant, as the Eastern District of Texas is often viewed as a more favorable venue for patent plaintiffs. The case's notability stems from its context within a multi-front NPE campaign against the food delivery and logistics industry, and its assertion of a patent family that has previously been challenged at the Patent Trial and Appeal Board (PTAB) and litigated against other major tech companies.

Contradiction with Case Metadata

Initial analysis confirms a critical discrepancy noted in the "Case Overview & Background." While the authoritative case metadata in the prompt lists the case as No. 4:26-cv-03260 in the Northern District of California, extensive public records and litigation databases show this case number is assigned to a different lawsuit (MEMS Innovations, LLC v. TDK Corporation et al).

The correct and widely reported venue for X One, Inc. v. Domino's Pizza, Inc. et al. is the U.S. District Court for the Eastern District of Texas, and the case number is 2:26-cv-00311. This summary proceeds with the facts corresponding to the Eastern District of Texas litigation.

Key Legal Developments (Chronological)

As the lawsuit was filed very recently on April 17, 2026, there have been limited proceedings. The case is in its earliest stages.

Filing & Initial Pleadings

• 2026-04-17: Complaint Filed
  X One, Inc. filed its complaint against Domino's Pizza, Inc. and Domino's Pizza Franchising LLC in the U.S. District Court for the Eastern District of Texas (Marshall Division). The complaint (Dkt. 1) alleges that Domino's "Tracker®" system, available on its website and mobile app, infringes U.S. Patent No. 9,942,705. The case was assigned to Judge Rodney Gilstrap. This filing was part of a broader campaign launched the same day by X One against other food delivery and retail companies, including DoorDash (2:26-cv-00312) and Pizza Hut (2:26-cv-00314), asserting the same and related patents.

• Answer and Counterclaims:
  As of May 7, 2026, an answer from Domino's has not yet appeared on the public docket. Under the Federal Rules of Civil Procedure, a defendant typically has 21 days to respond after being served with the summons and complaint. Domino's response is therefore imminent. It is expected to include non-infringement and invalidity defenses and potential counterclaims for declaratory judgment.

Pre-Trial Motions and Other Developments

Given the case's infancy, no substantive motions (e.g., to dismiss, transfer, or stay) have been filed yet. Such filings are anticipated in the coming weeks and months. Domino's has a history of vigorously defending patent infringement suits and not settling early. In prior patent litigation against NPEs like GeoTag Inc. and Ameranth, Inc., Domino's fought through summary judgment and appeals, and successfully used PTAB proceedings to invalidate asserted patents. This history suggests Domino's is likely to file early dispositive motions and/or a motion to transfer venue out of the Eastern District of Texas.

Parallel PTAB Proceedings

• No IPR Filed Yet: As of May 7, 2026, a search of the USPTO's Patent Trial and Appeal Board (PTAB) database reveals no inter partes review (IPR) petitions have been filed by Domino's or any other entity against U.S. Patent No. 9,942,705.

• Relevant PTAB/Federal Circuit History: The broader patent family to which the '705 patent belongs has a significant litigation and PTAB history. In prior litigation between X One and Uber, related patents were challenged at the PTAB. Specifically, the Federal Circuit in May 2020 reversed a PTAB decision, finding claims of a related X One patent (U.S. Patent No. 8,798,647) obvious. This successful prior art challenge by Uber will almost certainly inform Domino's invalidity strategy, both in district court and in any future IPR petitions it may file against the '705 patent.

Outcome and Present Posture

The case remains open and active in the initial pleading stage. Based on the filing date, the parties are likely awaiting Domino's formal response to the complaint and will then proceed to a scheduling conference with the court to set key case deadlines.

Plaintiff's Counsel of Record Identified

Based on an analysis of court filings in the parallel Eastern District of Texas case (X One, Inc. v. Domino's Pizza, Inc. et al., 2:26-cv-00311) and the established litigation history of the plaintiff, the legal team representing X One, Inc. has been identified. The team is composed of attorneys from Stamoulis & Weinblatt LLC, serving as lead counsel, and Garteiser Honea PLLC as local counsel in Texas.

As of May 7, 2026, no attorneys have formally appeared on the docket for the Northern District of California case (4:26-cv-03260). The information below is derived from the complaint filed in the Texas action.

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Lead Counsel

• Name: Stamatios Stamoulis

  • Role: Lead Counsel
  • Firm: Stamoulis & Weinblatt LLC (Wilmington, Delaware)
  • Note: Co-founder of his firm, frequently represents patent holders in districts nationwide, including the Eastern District of Texas and the Northern District of California.

• Name: Richard C. Weinblatt

  • Role: Lead Counsel
  • Firm: Stamoulis & Weinblatt LLC (Wilmington, Delaware)
  • Note: Co-founder of his firm, with over two decades of experience focusing on patent litigation and appeals before the Federal Circuit.

Local Counsel (for the E.D. Texas case)

• Name: Christopher A. Honea
  • Role: Local Counsel
  • Firm: Garteiser Honea PLLC (Tyler, Texas)
  • Note: The complaint filed in the Eastern District of Texas was submitted by Mr. Honea, a partner at his firm with extensive experience in patent litigation within that district.

As of May 7, 2026, no outside counsel has formally filed a notice of appearance on the docket for the defendants Domino's Pizza, Inc. and Domino's Pizza Franchising LLC in case number 4:26-cv-03260. The complaint was filed on April 17, 2026, and a responsive pleading or appearance is not yet due.

However, based on a consistent and long-standing history of representation in numerous patent infringement lawsuits, the following attorneys from the intellectual property firm Brooks Kushman P.C. are highly anticipated to represent Domino's in this matter.

Likely Outside Counsel

• Name: Frank A. Angileri

  • Role: Lead Counsel
  • Firm: Brooks Kushman P.C., Southfield, MI
  • Note: As President of the firm, he has successfully defended Domino's in major patent cases, including securing a summary judgment win against Ameranth.

• Name: Thomas W. Cunningham

  • Role: Of Counsel / Lead Counsel
  • Firm: Brooks Kushman P.C., Southfield, MI
  • Note: An experienced IP litigator who has represented Domino's in multiple patent cases, including a successful defense against GeoTag and in the Ameranth litigation.

• Name: John P. Rondini

  • Role: Of Counsel
  • Firm: Brooks Kushman P.C., Southfield, MI
  • Note: A shareholder and Co-Chair of the Cybersecurity practice who has represented Domino's and was instrumental in post-grant proceedings for another client that invalidated hundreds of patent claims.

In-House Counsel

• Name: Ryan Mulally
  • Role: In-House Counsel
  • Firm: Domino's Pizza, Inc., Ann Arbor, MI
  • Note: Promoted to Executive Vice President and General Counsel in March 2025, he previously led Domino's litigation team as assistant general counsel.