Exhibit 4 

 

Case 2:23-cv-00419-JRG Document 90-5 Filed 08/06/24 Page 1 of 3 PageID #: 1821
From: Randall Garteiser

To: Geyer, Kate

Cc: Damitio, Chris; chonea@ghiplaw.com; Machleidt, Dario

Subject: Symbology Innovations, LLC v. Valve Corporation and Gearbox Software, EDTX

Date: Thursday, November 16, 2023 8:48:03 AM

Attachments: 2023_11_16 venue discovery re sym v valve edtx.docx

Corrected Exemplar of unopposed motion for venue discovery.pdf

Exemplar of unopposed motion for venue discovery.pdf

**CAUTION: External Email**

Dear Ms. Geyer and additional Counsel for Valve Corp.,

Attached is a draft proposal for venue discovery crafted from other recent cases. This is a

direct result of Valve’s motion to dismiss based on Rule 30(b)(6).

A teleconference today or tomorrow is only required if your client does not agree with the

approach used in this District when the parties disagree whether venue is proper or not. I’ve

attached an exemplar we are using along with a Word version of the draft Plaintiff Symbology

is requesting in this case from your client Valve Corporation. 

In direct response to your letter, which we will craft a separate response to, just wanted to

make sure your law firm is aware that in 2015 Valve Corporation already stated in a written

settlement agreement that venue is proper in this district with respect to a prior patent

licensing agreement involving Display Technologies, LLC (Case No. 2:15-cv-00999). So it is

unclear why Valve believes suddenly venue is not proper here, when it has agreed to resolve

disputes about that prior agreement here. 

To be clear, Valve’s standard operating procedure related to its Freedom to Operate without

infringing patents of others is not at issue in the requested venue discovery. 

So please let us know so we can proceed accordingly with filing the draft unopposed, or in the

alternative, some times when you are available to discuss over the phone.

Be well,

Randall Garteiser

415.568.0553

On Nov 15, 2023, at 6:04 PM, Geyer, Kate <KGeyer@kilpatricktownsend.com>

wrote:

Counsel,

Case 2:23-cv-00419-JRG Document 90-5 Filed 08/06/24 Page 2 of 3 PageID #: 1822
Please see the attached letter.

Thank you,

Kate Geyer

kgeyer@ktslaw.com

1420 Fifth Avenue | Suite 3700 | Seattle, WA 98101

T 206 516 3094 | F 206 299 3458

Kilpatrick Townsend & Stockton LLP

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From: Machleidt, Dario <dmachleidt@kilpatricktownsend.com>

Sent: Monday, October 2, 2023 6:32 AM

To: rgarteiser@ghiplaw.com

Cc: Geyer, Kate <KGeyer@kilpatricktownsend.com>; Damitio, Chris

<CDamitio@kilpatricktownsend.com>; chonea@ghiplaw.com; rgarteiser@ghiplaw.com

Subject: Rothschild entities v. Valve, EDTX

Counsel,

Please see the attached letter.

Sincerely,

<image001.gif>

Dario Machleidt 

Kilpatrick Townsend & Stockton LLP 

Suite 3700 | 1420 Fifth Avenue | Seattle, WA 98101 

office 206 224 2857 | fax 206 374 2199

dmachleidt@kilpatricktownsend.com | My Profile | vCard

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' <2023-11-15 Ltr to Garteiser from Geyer.pdf>

Case 2:23-cv-00419-JRG Document 90-5 Filed 08/06/24 Page 3 of 3 PageID #: 1823