Exhibit 1 

Case 2:23-cv-00419-JRG Document 57-2 Filed 04/08/24 Page 1 of 3 PageID #: 1450
1

Geyer, Kate

From: Randall Garteiser <rgarteiser@ghiplaw.com>

Sent: Thursday, November 16, 2023 8:48 AM

To: Geyer, Kate

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

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

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,

Please see the attached letter.

Case 2:23-cv-00419-JRG Document 57-2 Filed 04/08/24 Page 2 of 3 PageID #: 1451
2

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 

My Profile | vCard 

Please note that my email address is changing. Please consider adding this new email to your safe 

senders list, downloading my vCard or sending me an email by using the address in my signature line. 

To learn more about our new visual identity, please visit us online at www.ktslaw.com 

 

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

'

Confidentiality Notice: 

This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C. 

Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any 

attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, 

any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY 

PROHIBITED. Please contact us immediately by return e-mail or at 404 815 6500, and destroy the original transmission and its attachments 

without reading or saving in any manner. 

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

Case 2:23-cv-00419-JRG Document 57-2 Filed 04/08/24 Page 3 of 3 PageID #: 1452