arXiv:2610.09395v1 Announce Type: new Abstract: This paper develops a distributionally robust optimization (DRO) framework for identifying the frequency response function (FRF) of an unknown linear time-invariant system from repeated noisy non-steady-state input-output measurements. Building on a recent frequency-domain extension of Willems' fundamental lemma, we formulate FRF estimation as a DRO problem, wherein robustness is desired with respect to the unknown probability distribution generating the noisy data. The proposed estimator computes FRF estimates by minimizing a convex upper bound on the DRO cost and allows for frequency-dependent calibration of the Wasserstein metric; the tractable upper bound consists of an empirical fit and a regularizer that penalizes the largest weighted sensitivity to spectral perturbations. Under suitable assumptions, we prove that the FRF estimation error is upper bounded by the optimal value of the DRO problem. The method is validated via a simple numerical study, which demonstrates improved performance under severely heavy-tailed noise.