Exhibit 3 

 

Case 2:23-cv-00419-JRG Document 90-4 Filed 08/06/24 Page 1 of 3 PageID #: 1818
From: Randall Garteiser

To: Machleidt, Dario

Cc: mikejones@potterminton.com; Shaun Hassett; Geyer, Kate; Damitio, Chris

Subject: Re: Today"s deadlines in Valve cases

Date: Monday, April 15, 2024 4:35:57 PM

**CAUTION: External Email**

We agree to the stipulation I sent around and with that we can file an extension in the hopes the parties file the

stipulation before Friday.

So if that’s a problem, we can file a motion for an extension opposed with the good cause being I was sick last

week.

> On Apr 15, 2024, at 6:10 PM, Machleidt, Dario <dmachleidt@ktslaw.com> wrote:

>

> Randy,

>

> Thanks for today's call. Regarding your request for a four-day extension "related to Quantum’s opposition to

MTD," Valve will agree to the extension if (1) QTI agrees to file an opposition brief (instead of another amended

complaint) to Valve's motion to dismiss by April 19, and (2) Symbology will not use the extension against Valve

when opposing Valve's motion to expedite in that case.

>

> Regarding the first point, as you acknowledged today, the Court's Venue Order (Dkt. 24) required a response brief

by March 11 (extended to the 21st). We hope it's no longer controversial that the Court expects the parties to

complete briefing on Valve's motion.

>

> We're considering your stipulation but won't be able to respond today.

>

> Please let us know if your clients will agree to these terms.

>

> Sincerely,

>

>

> Dario Machleidt

> dmachleidt@ktslaw.com

> Kilpatrick Townsend & Stockton LLP

> 1420 Fifth Avenue | Suite 3700 | Seattle,WA 98101

> T 206 224 2857 | F 206 374 2199

>

> www.ktslaw.com

>

> -----Original Message-----

> From: Randall Garteiser <rgarteiser@ghiplaw.com>

> Sent: Monday, April 15, 2024 9:00 AM

> To: Machleidt, Dario <dmachleidt@ktslaw.com>; mikejones@potterminton.com

> Subject: Today's deadlines in Valve cases

>

> **CAUTION: External Email**

>

> Hi Dario,

>

> 1. DCO, PO, Discovery Order.

>

> Has your client had a chance to revise the DCOs for SPIS and QTI in view of our discussion? We would

Case 2:23-cv-00419-JRG Document 90-4 Filed 08/06/24 Page 2 of 3 PageID #: 1819
appreciate your team circulating that, if so, to avoid filing something opposed.

>

> And with the PO, we will try to accommodate the restrictions as long as we have 450 pages of source code in total

and 50 pages continuous.

>

>

> 2. 4-day extension requested on Quantum’s Opposition.

>

> Separately, we’d appreciate a four-day extension on today’s deadline related to Quantum’s opposition to MTD.

With me being sick last week, we need additional time.

>

>

> 3. Times to meet and confer today.

>

> Please feel free to call me at 415.568.0553 anytime today to facilitate getting these documents on file today. I

have a state court appeal deadline today, so if I end talking with Mike Jones, I may need to ask for his advise.

> '

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>

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