Cal Bridge Inc v. Onecal

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cal Bridge, Inc. (Delaware)
  • Defendant: OneCal, SH.P.K. (Albania)
  • Plaintiff’s Counsel: Tucker Law®; McAndrews, Held & Malloy, Ltd.
• Case Identification: 1:24-cv-22361, S.D. Fla., 02/09/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of Florida because Defendant conducts substantial business in the district, offers its accused products to customers in Florida, and one or more users in Florida have purchased and used the accused products.
• Core Dispute: Plaintiff alleges that Defendant’s cloud-based calendar synchronization system infringes a patent related to privacy-sensitive, multi-calendar synchronization technology.
• Technical Context: The technology addresses the challenge of synchronizing events across disparate electronic calendar platforms (e.g., Google Calendar, Microsoft Outlook) while providing granular user control over privacy and notification settings.
• Key Procedural History: This Second Amended Complaint follows pre-suit correspondence in which Plaintiff sent a cease and desist letter in January 2024, to which Defendant’s counsel responded in February 2024. The complaint alleges that Defendant’s founder signed up for Plaintiff’s platform shortly before announcing the launch of the competing accused product.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,461,739 - “Privacy-Sensitive, Multi-Calendar Synchronization”

Issued October 4, 2022 (the “’739 Patent”)

The Invention Explained

• Problem Addressed: The patent’s background describes the technical difficulties in managing schedules across multiple electronic calendars hosted by different providers (e.g., Microsoft, Google) ( Compl. ¶¶9-10; ’739 Patent, col. 2:5-21). These providers often use proprietary, incompatible Application Programming Interfaces (APIs), which prevents direct synchronization between calendar hosts and forces users to rely on fragmented, client-side solutions that are often incomplete or raise privacy concerns (Compl. ¶10; ’739 Patent, col. 2:7-17).
• The Patented Solution: The invention is a centralized calendar synchronization system that acts as an intermediary between disparate calendar hosts (Compl. ¶16; ’739 Patent, FIG. 1). The system comprises a database service to store user-defined rules and a calendar synchronization service that receives notifications of events from a source calendar and, based on the stored rules, issues commands to create a corresponding event on a destination calendar (Compl. ¶16; ’739 Patent, abstract). This allows for automated, real-time synchronization with granular control over what event information is shared, such as full details, only the event subject, or merely a "busy" block (Compl. ¶19; ’739 Patent, col. 4:15-30).
• Technical Importance: This server-side approach overcomes the limitations of client-specific syncing and proprietary host APIs, enabling robust, cross-platform synchronization with integrated privacy and notification management controls Compl. ¶14

Key Claims at a Glance

• The complaint asserts independent claim 11 and dependent claims 13-17 Compl. ¶29
• Independent Claim 11 is directed to a system comprising:
  • Circuitry configured as a calendar synchronization service and a database service.
  • The database service is configured to store rules for propagating events between a first and second electronic calendar.
  • The rules determine what properties of an event are propagated and what notifications, if any, are added.
  • The synchronization service is configured to receive, via an API, a notification of a first event on the first calendar.
  • The synchronization service is configured to issue commands to the second calendar host to generate a second event according to the stored rules Compl. ¶31

III. The Accused Instrumentality

Product Identification

The "Accused OneCal System" or "OneCal," a cloud-based calendar synchronization service Compl. ¶¶21-22

Functionality and Market Context

• The Accused OneCal System is a service that automatically synchronizes a user's events across multiple calendar platforms, such as Google and Microsoft Outlook, in real-time Compl. ¶22 The complaint alleges the system operates on cloud computing infrastructure from Vercel and AWS Compl. ¶32 Users can define "sync configuration rules" to control how events are copied, including which properties (e.g., title, description, participants) are transferred and whether reminders are disabled for cloned events Compl. ¶¶33-35 A screenshot from OneCal's documentation illustrates the system synchronizing events between a "Google Calendar" and an "Outlook Calendar" Compl. p. 14
• The complaint alleges that OneCal markets itself as a direct competitor and "alternative" to Plaintiff's CalendarBridge product and targets Plaintiff's customers with a "switching discount" Compl. ¶24 The complaint includes a screenshot from Defendant's website with the heading "OneCal as a CalendarBridge alternative" Compl. p. 9

IV. Analysis of Infringement Allegations

'739 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The complaint alleges that the claim limitation "circuitry" is met by the use of third-party cloud computing infrastructure (e.g., AWS) Compl. ¶32 This raises the question of whether such general-purpose, distributed infrastructure constitutes the "circuitry configured to operate as" the claimed services, as contemplated by the patent.
• Technical Questions: The infringement theory relies on mapping OneCal’s user-facing "Sync Configuration" options, as shown in screenshots Compl. pp. 15, 19, directly to the "rules" required by the claims. A potential area of dispute may be whether these user-selectable settings perform the specific deterministic functions described for the "rules" in the patent specification.

V. Key Claim Terms for Construction

The Term: "circuitry configured to operate as a... service"

• Context and Importance: This term appears in the preamble of claim 11 and defines the fundamental components of the claimed system. Its construction is critical because the infringement allegation rests on Defendant’s use of third-party, general-purpose cloud infrastructure rather than dedicated or proprietary hardware.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a functional and potentially distributed implementation, stating that hardware resources "may reside on a single computer or may be distributed among a plurality of computers" (’739 Patent, col. 3:4-6). This language may support an interpretation that covers services running on shared cloud infrastructure.
  • Evidence for a Narrower Interpretation: The patent repeatedly uses the term "circuitry" throughout the claims, which could be argued to point toward a more specific physical or structural configuration rather than simply any hardware capable of running the described software.

The Term: "rules"

• Context and Importance: The "rules" are the core mechanism for controlling the privacy and notification settings of the propagated events, a central feature of the invention. The case will depend on whether OneCal's "sync configuration" settings Compl. p. 15 fall within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the rules in terms of user-selectable levels of information sharing, such as "free/busy," "subjects," or "full" details, and provides a user interface for configuring these options (’739 Patent, FIG. 5; ’739 Patent, col. 4:15-30). This suggests "rules" can be straightforward user-selected settings.
  • Evidence for a Narrower Interpretation: A party could argue that the term implies a more complex logical engine than simple on/off toggles. However, the patent’s own examples in the figures and description appear to define "rules" primarily by their functional output (i.e., the level of data propagated), which aligns with the functionality alleged in the complaint.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant provides the OneCal System and instructs users on how to use its allegedly infringing features through documentation and its user interface Compl. ¶¶54, 60 It also pleads contributory infringement, alleging the system is especially adapted for infringement and is not a staple article of commerce Compl. ¶62
• Willful Infringement: The complaint alleges willfulness based on both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged based on a January 2024 cease-and-desist letter, Plaintiff’s patent marking on its website, and allegations that Defendant's founder signed up for Plaintiff's service to copy its features before launching the accused product Compl. ¶¶55-57 Post-suit knowledge is alleged based on the filing of the complaint Compl. ¶55

VII. Analyst’s Conclusion: Key Questions for the Case

• A primary issue will be one of definitional scope: can the claim term "circuitry," which appears throughout the asserted claims, be construed to cover the third-party, general-purpose cloud computing infrastructure (e.g., AWS) that the complaint alleges constitutes the accused system?
• A central factual question will concern evidence of copying: to what extent will the complaint's detailed allegations—that Defendant’s founder accessed Plaintiff’s service shortly before launching a competing product with similar features and marketing Compl. ¶¶21, 24, 57—influence the judicial analysis of infringement, willfulness, and potential damages?
• A key question of claim construction will be whether the user-selectable "Sync Configuration" options in the accused product constitute the "rules" required by the patent, or if that term requires a more complex, logical backend implementation than what is alleged.