UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

QUANTUM TECHNOLOGY INNOVATIONS, 

L.L.C., 

Plaintiff, 

v. 

VALVE CORPORATION, GEARBOX 

SOFTWARE, L.L.C., 

Defendants. 

Civil Action No. 2:23-cv-425-JRG-RSP 

 JURY TRIAL DEMANDED 

UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFF’S COMPLAINT 

 Defendant Gearbox Software, L.L.C. (“Gearbox”) and Plaintiff Quantum Technology 

Innovations, L.L.C. (“Quantum”), by and through their undersigned counsel, respectfully file this 

Unopposed Joint Motion for an Extension of Time for Gearbox to Move, Answer or Otherwise 

Respond to Quantum’s Amended Complaint filed on March 15, 2024, (Dkt. 23). The current 

deadline for Gearbox to answer the Amended Complaint is June 12, 2024. The parties have 

conferred via email and agreed to a thirty (30) day extension, making the new answer deadline 

July 12, 2024. 

This is the fourth request for an extension to answer the Amended Complaint. Good cause 

exists because Quantum and Gearbox have jointly filed a motion to sever and stay Quantum’s 

claims against Gearbox (Dkt. 29), and have jointly filed a notice in an effort to clarify that same 

motion (Dkt. 47). Extending Gearbox’s time to answer will preserve judicial resources while the 

joint motion remains pending before the Court. The requested extension has not been made for 

Case 2:23-cv-00425-JRG-RSP Document 48 Filed 06/12/24 Page 1 of 3 PageID #: 708
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purposes of delay, and should not disrupt the schedule in this case. 

Accordingly, the parties respectfully request the Court grant this unopposed motion and 

extend the deadline to move, answer or otherwise respond to the Amended Complaint up to and 

through July 12, 2024. A proposed order is attached. 

Dated: June 12, 2024 

/s/Randall Garteiser 

Randall Garteiser, TBN 24038912 

Email: rgarteiser@ghiplaw.com 

Christopher A. Honea, TBN 24059967 

Email: chonea@ghiplaw.com 

M. Scott Fuller, TBN 24036607 

Email: sfuller@ghiplaw.com 

GARTEISER HONEA, PLLC 

119 W. Ferguson Street 

Tyler, Texas 75702 

Telephone: (903) 705-7420 

Facsimile: (903) 405-3999 

Attorneys for Plaintiff Quantum Technology 

Innovations, L.L.C. 

/s/Michael J. Sacksteder 

Michael J. Sacksteder, CSB No. 191605 

(Admitted to E.D. Tex.) 

Email: msacksteder@fenwick.com 

FENWICK & WEST LLP 

555 California Street, 12th Floor 

San Francisco, CA 94104 

Tel: (415) 875-2300 

Geoffrey Miller, TBN 24094847 

Email: gmiller@fenwick.com 

FENWICK & WEST LLP 

902 Broadway, 18th Floor 

New York, NY 10010 

Tel: (212) 921-2001 

Jessica M. Kaempf (WSBN 51666) 

(Admitted E.D. Tex.) 

Email: jkaempf@fenwick.com 

FENWICK & WEST LLP 

401 Union Street, 5th Floor 

Seattle, WA 98101 

Telephone: (206) 389-4510 

Attorneys for Defendant Gearbox Software, 

L.L.C.

Case 2:23-cv-00425-JRG-RSP Document 48 Filed 06/12/24 Page 2 of 3 PageID #: 709
CERTIFICATE OF CONFERENCE 

 The undersigned hereby represents and confirms that a conference was conducted with 

opposing counsel prior to filing this Motion and counsel indicated their agreement with the relief 

requested herein. 

Dated: June 12, 2024 /s/Michael J. Sacksteder 

Michael J. Sacksteder 

CERTIFICATE OF SERVICE 

 The undersigned hereby certifies that a true and correct copy of the above and foregoing 

document has been served to all counsel of record who are deemed to have consented to electronic 

service via the Court’s CM/ECF system. 

Dated: June 12, 2024 /s/Michael J. Sacksteder 

Michael J. Sacksteder 

Case 2:23-cv-00425-JRG-RSP Document 48 Filed 06/12/24 Page 3 of 3 PageID #: 710