THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

QUANTUM TECHNOLOGY 

INNOVATIONS, LLC,

Plaintiff,

v.

VALVE CORPORATION,

GEARBOX SOFTWARE, L.L.C.,

Defendants.

 CIVIL ACTION NO. 2:23-cv425-JRG

 JURY TRIAL DEMANDED

MOTION TO CONSOLIDATE BREIFING ON VALVE CORPORATION’S 

RULE 12(B)(3) MOTIONS TO DISMISS 

Plaintiff Quantum Technology Innovations, LLC (“Plaintiff”) respectfully moves 

to consolidate briefing on Valve’s three pending motions to dismiss. Initially, for the 

stipulated venue discovery the parties had agreed that venue discovery in the lead 

Symbology Innovations case would be controlling in SPIS and this case. Plaintiff’s 

counsel for QTI, SPIS and Symbology thought that was the plan all along, to have the 

briefing in the lead case control for all three (3) cases consistent with what the parties had 

done for venue discovery. But Valve Corporation disagrees and has refused a stipulation 

(Exhibit 1) to have the briefing for Valve’s motion to dismiss under Rule 12(b)(3) be 

decided by the lead case, titled Symbology Innovations, LLC v. Steam Corporation, Case 

2:23-cv-00419-JRG, Dkt. No. 55 (E.D. Tex. 2023). 

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Not until April 19, 2024, did Valve Corporation finally confirm it would not agree 

to the stipulated proposal for the Court to have one set of briefing in the lead case. Exhibit 

1. Plaintiffs SPIS, QTI and Symbology have explained to Valve Corporation that the 

complaints have not been updated to include all of the information gained during venue 

discovery in the SPIS and this case (QTI). Granting this motion will stop the need for

plaintiffs QTI and SPIS to have to amend, and defendant Valve Corporation to continue 

to re-file its motion to dismiss. This is consistent with the model docket control orders that 

have a deadline several months out from the original case management conference to 

allow the parties to amend their initial pleadings without seeking leave from the Court. 

Good cause exists as allowing the briefing in the lead case increases judicial 

economy and avoid inconsistent rulings and reduces motion practice, as Plaintiffs QTI and 

SPIS will need to embark on amending their complaints to include the additional factual 

information in the operative Symbology Complaint. Granting this motion will also avoid 

undue harm to Plaintiffs QTI and SPIS, and avoid the situation where the Court has 

inconsistent facts across the three cases to access venue related to Valve Corporation, 

when Valve Corporation is consistently the same party. It is not changing, nor should the 

Court’s ruling on venue. 

Also, granting this motion avoids a situation where there is an unnecessary waste 

of judicial resources in the event that the Court were to not find venue in these two cases 

but find it in the lead case, then Plaintiff would need to move opposed for leave to amend 

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its complaint to avoid a miscarriage of justice, which the Court should allow as 

amendments to pleadings should be ‘freely granted’ to resolve disputes on the merits, not 

technicalities.

In closing, Plaintiff asks that the briefing on Valve Corporation’s Rule 12(b)(3) 

motion in Symbology Innovations, LLC v. Valve Corporation, 2:23-cv-00419-JRG, Dkt. 

No. 55 be controlling to avoid inconsistent rulings relating to the same legal issue - is 

venue proper over Valve Corporation. 

Dated: April 20, 2024 Respectfully Submitted,

/s/ Randall Garteiser

Randall Garteiser 

 Texas Bar No. 24038912

 rgarteiser@ghiplaw.com

Christopher A. Honea

 Texas Bar No. 24059967

 chonea@ghiplaw.com

René A. Vazquez

 Virginia Bar No. 41988

 rvazquez@ghiplaw.com

M. Scott Fuller

 Texas Bar No. 24036607

 sfuller@ghiplaw.com

GARTEISER HONEA, PLLC

119 W. Ferguson Street

Tyler, Texas 75702

Telephone: (903) 705-7420

COUNSEL FOR PLAINTIFF

Case 2:23-cv-00425-JRG-RSP Document 41 Filed 04/20/24 Page 3 of 5 PageID #: 677
CERTIFICATE OF CONFERENCE

The undersigned attorney represents and confirms that a conference was conducted with opposing 

counsel prior to filing this Motion, and counsel indicated that it opposes this motion.

/s/ Randall Garteiser

Randall Garteiser

CERTIFICATE OF SERVICE

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

/s/ Randall Garteiser

Randall Garteiser

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