IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

SYMBOLOGY INNOVATIONS, LLC,

Plaintiff,

v. 

VALVE CORPORATION, GEARBOX 

SOFTWARE, L.L.C.,

Defendants.

§

§

§

§

§

§

§

§

§

§

§

CIVIL ACTION NO. 2:23-CV-00419-JRG

ORDER

Before the Court is the Unopposed Motion for Leave to Conduct Expedited Venue 

Discovery and Extension of Time to Respond to Motion to Dismiss (the “Motion”) filed by 

Plaintiff Symbology Innovations, LLC (“Plaintiff” or “Symbology”). (Dkt. No. 23). In the Motion, 

Plaintiff requests leave to conduct limited, expedited venue discovery in this matter, and for an 

extension of time to respond to Defendant Valve Corporation’s (“Defendant” or “Valve”) Motion 

to Dismiss (Dkt. No. 11) (the “Motion to Dismiss”). (Dkt. No. 23 at 1). Plaintiff informs the Court 

that there are two other cases [Social Position Input Systems v. Valve Corp. et al., No. 2:23-cv00425 (E.D. Tex. Sept. 18, 2023) and Quantum Technology Innovations v. Valve Corp. et al., No. 

2:23-cv-00422 (E.D. Tex. Sept. 18, 2023)] filed against Defendant in this district by entities that 

are also “owned in their entirety by Patent Asset management, LLC and are represented in their 

cases against Valve by the same undersigned counsel.” (Id. at 2). Plaintiff further informs the Court 

that “the venue allegations in the complaints filed by Symbology, Social Positioning Input 

Systems, and Quantum Technology Innovations are substantively identical, and Valve disputes 

that venue is proper in this District for any of the three cases.” (Id.). As such, Plaintiff represents 

Case 2:23-cv-00419-JRG Document 24 Filed 12/13/23 Page 1 of 3 PageID #: 186
2

to the Court that the parties “stipulate that the venue discovery proposals below will be applied to 

all three cases,” and that they further “stipulate that the arguments made in Valve’s Motion to 

Dismiss in the above-captioned case (Case No. 23-419, Dkt. No. 11), Plaintiff’s Response, and 

any subsequent briefing be applied with equal force to all three cases.” (Dkt. No. 23 at 2). Plaintiff 

represents that the proposed discovery is narrowly focused to resolve the parties’ disputes. (Id.). 

The Motion is unopposed. (Id. at 1, 4).

Having considered the Motion, and noting its unopposed nature, the Court finds that it 

should be and hereby is GRANTED. It is ORDERED that the parties may conduct limited, 

expedited venue-related discovery subject to the agreements set forth in the Motion (Dkt. No. 23

at 2-3) as follows:

1. Venue-related discovery shall be completed within seventy-five (75) days of the 

issuance of this Order; 

2. Venue-related discovery shall be limited to the issues raised in Defendant’s Motion to 

Dismiss and associated exhibits, information and Defendant’s ties to the Eastern District 

of Texas;

3. Plaintiff may serve no more than five (5) interrogatories and ten (10) document requests 

to Defendant by December 15, 2023;

4. Defendant shall respond to Plaintiff’s discovery requests and produce, subject to 

Defendant’s objections, responsive documents, if any, by January 20, 2024;

5. Plaintiff may conduct a Rule 30(b)(6) deposition of Defendant, solely related to the 

topics in paragraph 2, limited to five (5) hours total on the record on or before January 

27, 2024;

Case 2:23-cv-00419-JRG Document 24 Filed 12/13/23 Page 2 of 3 PageID #: 187
3

6. The foregoing discovery shall not count toward the discovery limits set forth in Court’s 

standing Discovery Order; and

7. Plaintiff’s response to the Motion to Dismiss shall be filed within fifteen (15) days of 

issuance of the final transcript of the referenced Rule 30(b)(6) deposition, or within 

eighty-nine (89) days of the issuance of this Order, whichever is later.

.

____________________________________

RODNEY GILSTRAP

UNITED STATES DISTRICT JUDGE So ORDERED and SIGNED this 13th day of December, 2023.

Case 2:23-cv-00419-JRG Document 24 Filed 12/13/23 Page 3 of 3 PageID #: 188