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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

SYMBOLOGY INNOVATIONS LLC

Plaintiff,

v.

VALVE CORPORATION, 

GEARBOX SOFTWARE, LLC

Defendant.

Civil Action No. 2:23-cv-419-JRG

JURY TRIAL DEMANDED

VALVE’S UNOPPOSED MOTION TO STAY BRIEFING ON ITS 

MOTION FOR SANCTIONS PENDING RESOLUTION OF ITS 

MOTION TO DISMISS FOR IMPROPER VENUE IN RELATED CASES

Valve Corporation (“Valve”) respectfully requests that the Court stay further briefing on 

its motion for sanctions (Dkt. 85) until after the Court has resolved Valve’s motion to dismiss for 

improper venue (Dkt. 55)1. In doing so, Valve respectfully shows the Court the following: 

The issues raised in Valve’s motion for sanctions are closely tied to the facts and 

arguments addressed in its motion to dismiss. And, more specifically, Valve’s contention that the 

Third Amended Complaint contained false and frivolous venue allegations, and that 

Symbology’s and its counsel acted in an improper manner which prevented the timely resolution 

of Valve’s Motion to Dismiss. See Dkt. 85.

On April 22, 2024, in response to Symbology’s Third Amended Complaint (Dkt. 52), 

Valve served its Rule 11 letter and motion for sanctions on Symbology’s counsel. In response, 

Symbology chose to not withdraw the Third Amended Complaint. The safe harbor period for 

Symbology to do so expired on May 13, 2024. Fed. R. Civ. P. 11(c)(2).

1 Symbology does not oppose Valve’s motion.

Case 2:23-cv-00419-JRG Document 86 Filed 07/30/24 Page 1 of 4 PageID #: 1783
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On July 26, 2024, Symbology voluntarily dismissed its case against Valve with prejudice. 

Dkts. 82, 84. However, despite Symbology’s notice of voluntary dismissal, Valve’s motion to 

dismiss remains pending as it applies to two related cases in this Court: Social Positioning Input 

Sys., LLC v. Valve Corp. et al., Case No. 2:23-422 (E.D. Tex. Sept. 19, 2023) (the “Social 

Positioning” case); and Quantum Tech. Innovations, LLC v. Valve Corp et al., Case No. 2:23-

425 (E.D. Tex. Sept. 19, 2023) (the “Quantum” case). The same counsel represents plaintiffs in 

all of these cases. 

In view of the procedural posture between the three relevant cases (Symbology, Social 

Positioning, and Quantum), Valve desires to bring to the Court’s attention that Rule 11 issues 

remains to be decided in this case despite Plaintiff’s voluntary dismissal. At the same time, 

however, Valve recognizes that because its motion for sanctions is closely tied to the facts and 

arguments in its motion to dismiss, the Court’s consideration of Valve’s motion for sanctions 

after the Court’s ruling on Valve’s motion to dismiss best promotes judicial economy and avoids

duplicative work. 

Accordingly, Valve respectfully moves this Court to stay further briefing of Valve’s 

motion for sanctions until the Court has ruled on the motion to dismiss in the Quantum and 

Social Positioning cases. Staying resolution of the sanctions motion serves important goals of 

judicial economy and efficiency because any findings this Court makes as part of its ruling on 

Valve’s motion to dismiss will likely relate to whether to impose sanctions against Symbology 

and its counsel.

Case 2:23-cv-00419-JRG Document 86 Filed 07/30/24 Page 2 of 4 PageID #: 1784
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Dated: July 30, 2024 Respectfully submitted,

/s/ Shaun W. Hassett, with permission for 

Kathleen R. Geyer

Michael E. Jones

SBN: 10929400

Shaun W. Hassett

SBN: 24074372

Potter Minton

102 North College, Ste. 900

Tyler, Texas 75702

903-597-8311 (telephone)

mikejones@potterminton.com

shaunhassett@potterminton.com

Dario A. Machleidt

Kathleen R. Geyer

Christopher P. Damitio 

Kilpatrick Townsend & Stockton

1420 Fifth Avenue Suite 3700 

Seattle, WA 98101 

Telephone: (206) 467-9600 

Facsimile: (206) 623-6793 

DMachleidt@kilpatricktownsend.com

KGeyer@kilpatricktownsend.com 

CDamitio@kilpatricktownsend.com 

Attorneys for Defendant

Valve Corp.

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CERTIFICATE OF CONFERENCE

Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-7(i), I hereby certify 

that, on July 30, 2024, counsel for Valve met and conferred with counsel for Plaintiff regarding 

the subject of the above motion. Plaintiff indicated that they did not oppose the motion.

/s/ Shaun W. Hassett

Shaun W. Hassett

Case 2:23-cv-00419-JRG Document 86 Filed 07/30/24 Page 4 of 4 PageID #: 1786