IP Law Daily, PATENT—S.D. Fla.: Calendar syncing patent was not invalid for being directed at an abstract idea, (Jan 27, 2026)

By Kevin M. Finson, J.D.

Claims relating to a system that synchronizes multiple electronic calendars across multiple services related to technological improvements.

A producer of an electronic calendar synchronization service failed to show a competitor’s patent was invalid at the pleading stage, the U.S. District Court in Miami has held. The asserted claims were at least plausibly alleged to relate to technological improvement rather than to the abstract idea of data manipulation (Cal Bridge, Inc. v. OneCal, No. 1:24-cv-22361-RKA (S.D. Fla. Jan. 24, 2026)).

Cal Bridge, Inc. (Cal Bridge) was the owner of U.S. Patent No. 11,461,739 (the ’739 patent), which claimed a system for synchronizing multiple electronic calendars hosted by disparate services, in order to allow a user to see his or her entire set of calendars at once. OneCal was a competing, cloud-based, calendar synchronization service. Cal Bridge brought suit for patent infringement, false advertising and unfair competition under the Lanham Act, unfair competition under Florida law, and violation of Florida’s Deceptive and Unfair Trade Practices Act. OneCal moved to dismiss.

Abstract idea. OneCal argued that the asserted claims of the ’739 patent were invalid because they were directed to the abstract idea of manipulating data in databases, which could be accomplished by pen and ink. Applying the Alice test, the court found that OneCal had “grossly oversimplified” the ’739 patent, noting that it specifically improved prior art computer systems by determining what information was automatically synched and what was not, and achieved selective synchronization to maintain user privacy by sharing only desired details between calendars. This was not merely paper calendars implemented on a computer. The court also found that, if it were to reach step two of the Alice test, Cal Bridge had alleged a unique use of conventional computer components by adding to the prior art communication via API a system for generating new calendar events according to a specified set of rules. The court therefore denied the motion to dismiss the patent infringement claim.

Shotgun pleading. OneCal argued that all three of the remaining claims were an impermissible “shotgun pleading” because they each incorporated by reference all of the prior allegations in the complaint. The court agreed, finding that because each of these claims incorporated all prior allegations, OneCal had not received adequate notice of the claims against it and grounds upon which each claim rested. The pleading failed to meet the standards of Fed. R. Civ. P. 8(a)(2) and 10(b), which required a short and plain statement of the claim as well as limitation of each claim “as far as practicable” to a single set of circumstances.

The court denied the motion to dismiss as to the patent infringement claim and struck the remaining claims as shotgun pleadings, after which it noted that the stricken claims also failed to state a claim due to being bare recitations of the elements and that the state law claims were potentially preempted. Cal Bridge was granted leave to amend.

The Case is No. 1:24-cv-22361-RKA.

Judge: Altman, R.

Attorneys: Matthew Sean Tucker (Tucker Law, P.A.) for Cal Bridge, Inc. Martin B. Sipple (Ausley & McMullen PA) for OneCal.

Companies: Cal Bridge, Inc.; OneCal

Cases: Patent FloridaNews