Exhibit 19.1

Insider Trading Policy

Adopted November 2015

and updated as of December 2025

Policy Statement: All, directors, officers, employees and certain consultants (collectively, “Insiders”) of XTI Aerospace, Inc. and its subsidiaries (collectively, the “Company”) are prohibited from buying and selling securities of the Company, or advising others to do so, while in possession of material, non-public information.

In addition, ALL Insiders - regardless of position, access to information, or trading history, must obtain prior written pre-clearance from the Company before engaging in any purchase, sale, or other transaction involving the Company's securities, even when not in possession of material, non-public information, unless such transaction is executed pursuant to a properly approved Rule 10b5-1(c) trading plan under the Securities Exchange Act of 1934, as amended (the “Exchange Act”).

This policy is intended to prevent both actual violations of insider trading laws and the appearance of improper trading activity and may be amended from time to time.

General

The U.S. federal securities laws prohibit (i) trading in securities on the basis of material, non-public information and (ii) revealing such information to others who then act upon it. These restrictions, apply to all transactions in publicly traded securities in all markets (including U.S. and foreign markets). They apply to transactions effected, directly or indirectly, by you or any member of your immediate family or household. They also apply to transactions through accounts over which you or a member of your immediate family or household has trading discretion or influence. There are severe criminal penalties for violations of these rules.

What is “Inside” Information?

“Inside” information includes anything you become aware of because of your special relationship with the Company as an officer, director or employee of the Company, which has not been disclosed to the public. The information may be about the Company or any of its subsidiaries or other affiliates. It may also include information you learn about another company, for example, companies that are current or prospective customers or suppliers to the Company or any of its subsidiaries or with which the Company or any of its subsidiaries may be in negotiations regarding a potential transaction.

What is “material” Information?

Trading in securities while in possession of “inside” information is not a basis for liability unless the information is “material.” Information is material if there is a substantial likelihood that a reasonable investor would think such information important in deciding whether to buy, sell or hold stock, or if it could affect the market price of the stock. Either positive or negative information may be material. Information can be material even if it relates to future speculative or contingent events and even if it is significant only when considered in combination with publicly available information. If you are unsure whether information is material, assume it is material.

Although there is no precise, generally accepted definition of materiality, some examples of material information include, but are not limited to:

“Inside” information could be material because of its expected effect on the price of the Company’s stock, the stock of another company not related to the Company, or the stock of several such companies. In addition, the resulting prohibition against the misuse of “inside” information includes not only restrictions on trading in the Company stock, but restrictions on trading in the stock of such other companies affected by the “inside” information.

What is “non-public” Information?

In order for information to qualify as “inside” information, it must not only be “material,” it must also be “non-public.” Non-public information is information that has not yet been made public by the Company. Information only becomes public when the Company makes an official announcement (i.e., in a publicly accessible conference call, a press release or in filings made with the Securities and Exchange Commission (“SEC”)), and people have had an opportunity to see or hear it. The circulation of rumors or “talk on the street,” even if accurate, widespread and reported in the media, does not constitute public disclosure. Similarly, only disclosing part of the information does not constitute public dissemination. So long as the any material portion of the information has yet to be publicly disclosed, the information is deemed “non-public” and may not be misused. Therefore, you should not buy or sell stocks or other securities before the public announcement of material information.

The Company does not consider quarterly and annual earnings results “public” until the first business day after a press release has been issued. Similarly, other material information will not be considered public until the first business day after the public release of such information.

If you are unsure whether information is material or non-public, you must contact the Company’s Finance department at notices@xtiaerospace.com before making any decision to disclose such information (other than to persons who need to know it) or to trade in or recommend securities to which that information relates or assume that the information is material.

Prohibition Against Trading While In Possession of Material Non-Public Information

You may not purchase or sell stocks or other securities of the Company or of any other company when you are aware of any material, non-public information about that company, no matter how you learned the information. You also must not “tip” or otherwise give material, non- public information to anyone, including people in your immediate family, friends or anyone acting for you (such as a stockbroker). Exercising stock options granted under the Company’s employee stock incentive plans for cash or the delivery of previously owned Company stock is exempted from this prohibition; provided, however, that the sale of any shares issued on the exercise of Company-granted stock options and any cashless exercise of Company-granted options are subject to the trading restrictions under this Policy.

Mandatory Pre-Clearance Policy for All Insiders

All Insiders of XTI Aerospace, Inc. and its subsidiaries are required to obtain prior written pre-clearance before engaging in any transaction involving the Company's securities.

This requirement applies to all purchases, sales, transfers, gifts, equity derivative transactions, or other dispositions of Company securities, whether conducted directly or indirectly, and regardless of whether the individual believes they are in possession of material, non-public information.

Insiders must request pre-clearance by contacting the Company's Finance Department notices@xtiaerospace.com. Approval must be received before initiating any transaction.

Pre-clearance approval, if granted, will generally be valid for three (3) business days, provided that the Employee remains not in possession of material, non-public information during that period. If the transaction is not completed within that timeframe, new pre-clearance must be obtained.

If pre-clearance is denied, the Insider may not engage in the transaction and may not disclose the denial or any related restrictions to any other person. The Insider may reapply for pre-clearance at a later date when trading restrictions may no longer be applicable.

Restricted trading periods are periods designated by the Company as times in which all Insiders may not trade in the Company's stock regardless of any actual possession or non-possession by Insiders of material, non-public information. Exceptions to this prohibition will be considered for emergency reasons by the Company. These restricted trading periods are instituted by the Company for a variety of reasons. One such restricted trading period is instituted prior to the Company releasing its financial results. This restricted trading period begins on the 20th day of the third month of every calendar quarter and lasts until one full trading day after the Company releases its financial results for the completed quarter or year.

In addition to making sure a restricted trading period is not in effect, the pre-clearance procedure is necessary to assist all Insiders in preventing violations of the Section 16(b) short-swing profit rule, as applicable. As you may know, officers and directors will be held liable to the Company for any “short-swing profits” resulting from a non-exempt purchase and sale or sale and purchase within a period of less than 6 months.

In sum, it is critical that every Insider obtain pre-clearance of any trading to prevent both inadvertent Section 16(b) or insider trading violations and to avoid even the appearance of an improper transaction (which could result, for example, when an officer or director engages in a trade while unaware of a pending major development).

No Margin Purchases.

Securities held in a margin account may be sold by the broker without the customer’s consent if the customer fails to meet a margin call. Similarly, securities pledged (or hypothecated) as collateral for a loan may be sold in foreclosure if the borrower defaults on the loan. Because a margin sale or foreclosure sale may occur at a time when the customer or borrower is aware of material non-public information or otherwise is not permitted to trade in the Company’s securities, all Insiders are prohibited from holding the Company’s securities in a margin account or pledging the Company’s securities as collateral for a loan.

No Short Sales.

Short selling is the act of borrowing securities to sell with the expectation of the price dropping and the intent of buying the securities back at a lower price to replace the borrowed securities. All Insiders (whether or not they are in possession of material nonpublic information) are prohibited from selling short the Company’s securities.

No Hedging.

Hedging transactions allow the holder to lock in a value for the security in exchange for protection against drastic upside or downside price movement. Giving up the full risks and rewards of security ownership can result in the perception that the holder no longer has the same interests as the company’s stockholders.

Therefore, Insiders may not enter into hedging or monetization transactions or similar arrangements with respect to Company securities.

No Insider may buy or sell XTIA securities at any time without first obtaining pre-clearance from the Company.

Pre-Clearance Policy for Rule 10b5-1 Plans

Notwithstanding the prohibition against insider trading, Rule 10b5-1 under the Exchange Act and the Company’s policy permit Insiders to trade in Company securities regardless of their awareness of “inside” information if the transaction is made pursuant to a pre-arranged trading plan that was entered into when the Insider was not in possession of material nonpublic information. Insiders may not implement a trading plan under Rule 10b5-1 at any time, without prior clearance. Before entering into a trading plan you must the Company’s Finance department at notices@xtiaerospace.com, to inquire if a restricted trading period is in effect and to obtain pre-clearance of the contemplated plan. Insiders may only enter into a trading plan when they are not in possession of material, non-public information. In addition, Insiders may not enter into a trading plan during a pension fund blackout period. Once a trading plan is pre-cleared, trades made pursuant to the plan will not require additional pre-clearance, but only if the plan specifies the dates, prices and amounts of the contemplated trades or establishes a formula for determining dates, prices and amounts.

What Are The Penalties for Insider Trading?

In 1988, Congress passed the Insider Trading and Securities Fraud Enforcement Act of 1988, providing for increased criminal penalties for person engaged in insider trading. In addition, non-criminal civil actions may be brought by private individuals or the SEC. The consequences of an insider trading violation can be devastating and can ruin both your professional and personal life. The SEC may investigate any suspicious trading including whether an individual is trading 1,000,000 shares or 10 shares. No executive officer, director or employee is exempt from an SEC investigation and penalties (i.e., jail sentence of up to 10 years, returns of profits, fines, etc.). A person can be subject to penalties even if he or she does not personally benefit from the violation (i.e., if the violation only involved passing the information to someone else, called a "tippee") In addition, a violation of these insider trading restrictions can be expected to result in serious disciplinary actions by the Company (i.e., termination).

How Can I Protect Material Non-public Information?

Material non-public information (and all other confidential information of the Company) should be communicated only to those people who need to know it for a legitimate business purpose and who are authorized to receive such information in connection with their responsibilities to the Company.

The following practices should be followed to help prevent the misuse of material non-public information and other types of confidential information:

What If I Have Any Questions About Insider Trading Restrictions?

Insiders of the Company should at all times avoid even the appearance of impropriety with respect to trading in the Company stock or the securities of any of the companies with whom the Company or its subsidiaries does business. When there are any questions as to a potential application of insider trading laws or any other restrictions on insider trading or if you know of a suspected violation of these laws, please contact the Company’s Finance department at notices@xtiaerospace.com.

ACKNOWLEDGMENT AND CERTIFICATION

The undersigned does hereby acknowledge receipt of XTI Aerospace’s Insider Trading Policy and understands that it may be amended from time to time. The undersigned has read and understands (or has had explained) such Policy and agrees to be governed by such Policy (as such Policy may be amended) at all times in connection with the purchase and sale of securities and the confidentiality of nonpublic information.