Each calendar creation call takes approximately 2s to complete.  Once I hit 
the quota error, if I wait an hour and try again, I get the same error on 
creation of the first calendar.  Only when I wait until the next day will 
the error go away.

I had raised a support ticket, quoting the maximum of 37, and Google 
technical support took no issue with the cap that I hit.  Either they 
confirmed by omission that the limit is in fact 37, or they don't actually 
know the limit and are assuming based on the error response that I received.

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