In March 2026, China's National Intellectual Property Administration (CNIPA) invalidated two patents owned by Irdeto B.V., a Dutch digital security company, at the request of DJI Innovation Technology. The patents—one covering "detecting modifications to content items" and another on "challenge-response methods"—were both declared fully invalid on grounds of lack of novelty and inventive step.

This didn't happen in isolation. DJI filed the invalidation requests as part of a coordinated global counterattack. Irdeto had sued DJI at the Unified Patent Court (UPC) Mannheim Local Division in April 2025, alleging that DJI's drone security mechanisms infringed European Patent EP2831787. DJI responded by filing patent infringement claims against Irdeto in Texas federal court in October 2025, targeting four U.S. patents, and simultaneously launching invalidation proceedings against Irdeto's Chinese portfolio.

The CNIPA decisions represent a turning point. Two of Irdeto's four asserted patents in China are now gone. A third remains under review. One survived CNIPA's examination in March 2026.

Key outcomes so far: CNIPA invalidated two Irdeto patents (January 7 and March 11, 2026). Irdeto's European UPC action remains pending. DJI's U.S. counterclaims are active. Irdeto filed a declaratory judgment action in Michigan in February 2026.

For foreign companies watching this case, the implications are concrete and worth examining closely.

What This Means for Foreign Companies Operating in or Targeting China

China's Patent Invalidation System Can Work Offensively

Many foreign companies assume China's patent invalidation system is something to fear—technically opaque, politically unpredictable. DJI's wins flip that assumption.

DJI used CNIPA invalidation proactively. Irdeto, apparently caught off guard, did not submit written responses in the invalidation proceedings and did not attend oral hearings. The patents fell anyway.

The lesson: CNIPA invalidation can be a legitimate offensive tool, not just a defensive last resort. For foreign companies with strong patent portfolios, this suggests you have more leverage in China than you might think. For foreign companies facing patent assertions from Chinese entities, it confirms that challenging the other side's Chinese patents is a viable path.

NPE Behavior Is Changing—And China Is Part of the Reason

Irdeto is not a typical non-practicing entity. It has real products in digital security and content protection. But its strategy—filing patents, asserting them across multiple jurisdictions, and seeking licensing revenues—mirrors NPE patterns.

DJI's approach suggests Chinese companies are no longer passive targets in NPE-style litigation. DJI sent two formal letters to Irdeto asserting that DJI's standard-essential patents (SEPs) read on Irdeto's products. DJI explicitly framed this as an invitation to cross-licensing, not just a defensive move.

This is a shift. A few years ago, a Chinese company absorbing patent pressure from a Western firm would have focused on settlement. DJI went on offense.

The Three-Jurisdiction Trap Is Real

Irdeto started this in Europe. DJI countered in the U.S. Both companies are now litigating in three separate systems with different procedural rules, different timelines, and different evidentiary standards.

For foreign companies: if you have exposure to multi-jurisdiction disputes with Chinese entities, plan the sequence carefully. Filing in Europe does not give you homecourt advantage. Your opponent may be better resourced for parallel proceedings than you are, especially if they can coordinate Chinese invalidations to erode your patent portfolio while you litigate elsewhere.

What Foreign Companies Should Do Now

If you hold patents that could read on Chinese products

Your Chinese portfolio needs active management. Monitor CNIPA invalidation filings quarterly. Respond to invalidation notices—DJI won partly because Irdeto failed to mount a defense. Silence is not strategic in China's patent invalidation system.

Consider whether your patents could be cross-licensed against Chinese SEP portfolios. DJI offered this path; Irdeto apparently declined. The outcome suggests DJI may have been sincere about the offer.

If you are facing patent assertions from Chinese entities

Challenge their Chinese patents early. The CNIPA invalidation system offers a credible path to neutralize threats at the source. Do not assume Chinese patent quality is uniformly high—it varies significantly. Many foreign patent holders overestimate the strength of Chinese patents they have not examined closely.

Coordinate invalidation timing with parallel litigation in other jurisdictions. If you can invalidate a Chinese patent before or during foreign proceedings, you shift the negotiation dynamics significantly.

If you are considering asserting patents against Chinese companies

The DJI-Irdeto case shows you may face immediate counterattack. Irdeto sued in Europe; DJI filed in Texas and started invalidations in China within months. The three-jurisdiction trap works both ways.

Build in contingency plans for patent invalidation exposure in China before filing. If your patents there are weak, Chinese defendants will find out fast.

The Broader Commercial Dynamics

Irdeto's original bet was straightforward: assert patents in a jurisdiction where DJI has significant market exposure, negotiate a licensing deal, collect revenue. DJI refused to play that game.

What DJI did instead—coordinated offensive in multiple directions—represents a more sophisticated IP strategy than most foreign companies expect from Chinese firms. DJI leveraged its own patent portfolio (including SEPs), used CNIPA invalidation to erode Irdeto's Chinese position, and filed in U.S. federal court to create settlement pressure.

This matters for how foreign companies assess IP risk in China. Chinese companies increasingly have patent portfolios worth defending. They have legal sophistication. They have resources for parallel proceedings. The old playbook—file in Europe or the U.S., pressure a Chinese company in negotiations—is less reliable than it used to be.

The DJI-Irdeto dispute is not just about drones or digital security. It is a case study in how global patent warfare now works when both sides have substantive IP portfolios and the resources to fight across multiple jurisdictions. For foreign companies, the practical implications are clear: manage your Chinese patents actively, consider offensive invalidation strategies when facing Chinese assertions, and plan multi-jurisdiction sequences carefully rather than assuming homecourt advantage anywhere.

What Happens Next

Irdeto and DJI are still litigating. The European UPC case is pending. DJI's U.S. claims are active. Irdeto's declaratory judgment action in Michigan adds another layer.

The most likely outcome remains negotiated settlement—probably involving some form of cross-licensing. But the path to get there is now different from what Irdeto likely expected when it filed in Europe in April 2025. DJI has weakened Irdeto's Chinese position, filed claims in U.S. federal court, and shown it will fight on all fronts.

Whether this case resolves in months or years, it will shape how both sides approach patent disputes going forward. For foreign companies watching, the lesson is not to underestimate Chinese companies in patent warfare—and to start treating China's invalidation system as a tool available to you, not just a threat to your own portfolio.