Cal Bridge, Inc. v. OneCal

Summary

The United States District Court for the Southern District of Florida partially grants and partially denies OneCal’s motion to dismiss Cal Bridge, Inc.’s amended complaint. The court allows the patent-infringement claim concerning the ’739 patent to proceed, finding that patent eligibility cannot be resolved at this stage, but strikes the false-advertising and unfair-competition claims as an impermissible shotgun pleading and because they are inadequately pleaded. Cal Bridge is granted an opportunity to amend those claims.

Holdings

1. At the pleading stage, OneCal failed to show that the asserted patent claims were patent-ineligible. The allegations plausibly showed that Claim 11 was directed to a specific improvement in computer functionality—bridging incompatible calendar hosts through rule-based synchronization—and plausibly alleged an inventive concept under Alice Step Two.
2. Counts II through IV constituted an impermissible shotgun pleading because each incorporated all preceding allegations, including the allegations of the patent-infringement count, without adequately separating the factual bases for the different causes of action.
3. Count II did not plausibly state a Lanham Act false-advertising claim because it alleged deception, materiality, consumer impact, and injury largely in conclusory terms. The reverse-passing-off and trade-dress theories also failed as pleaded.
4. The court did not decide whether Counts III and IV were preempted. It held only that the counts, as pleaded, were vulnerable to a preemption challenge because they incorporated the patent-infringement allegations wholesale and did not clearly identify the non-patent conduct supporting the state-law claims.

Questions Presented

1. Whether the asserted claims of U.S. Patent No. 11,461,739 were patent-ineligible under 35 U.S.C. § 101 and the Alice framework at the Rule 12(b)(6) stage.
2. Whether Counts II through IV were impermissible shotgun pleadings under Federal Rules of Civil Procedure 8(a)(2) and 10(b).
3. Whether Count II plausibly stated Lanham Act claims for false advertising, reverse passing off, or trade-dress infringement.
4. Whether Counts III and IV were inadequately separated from the patent-infringement theory and vulnerable to federal patent-law preemption.

Disposition

other