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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-RSP

JURY TRIAL DEMANDED

FILED UNDER SEAL

DECLARATION OF KATHLEEN R. GEYER IN SUPPORT OF 

DEFENDANT VALVE CORPORATION’S MOTION TO DISMISS UNDER 

FEDERAL RULE OF CIVIL PROCEDURE 12(B)(3) FOR IMPROPER VENUE

I, Kathleen R. Geyer, hereby declare as follow:

1. I am an attorney at the law firm of Kilpatrick, Townsend, & Stockton. I am 

counsel for Valve Corporation (“Valve”). I am admitted to practice before this Court, and I have

personal knowledge of the matters set forth herein. If called as a witness, I could and would 

testify competently thereto.

2. Attached as Exhibit 1 is a true and correct copy of the Global Settlement and 

License Agreement, executed between Valve Corporation, Display Technologies, LLC, and 

Leigh Rothschild on January 11, 2016.

3. Attached as Exhibit 2 is a true and correct copy of an executed Steam Site 

Licensing Program License dated September 6, 2018, bearing Bates numbers 

VALVE_SYM_00001206-10.

4. Attached as Exhibit 3 is a true and correct copy of excerpts of the Rule 30(b)(6) 

Deposition of Valve’s corporate representative, Christopher Schenck, taken on February 5, 2024.

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5. Attached as Exhibit 4 is a true and correct copy of an agreement between Valve 

and , bearing Bates numbers 

VALVE_SYM_00001345-54. 

6. Attached as Exhibit 5 is a true and correct copy of an 

 bearing Bates numbers VALVE_SYM_00001267-78. 

7. Attached as Exhibit 6 is a true and correct copy of an agreement between Valve 

and , bearing Bates numbers 

VALVE_SYM_00001301-44. 

8. Attached as Exhibit 7 is a true and correct copy of an agreement between Valve 

and , bearing Bates numbers 

VALVE_SYM_00001240-66. 

9. Attached as Exhibit 8 is a true and correct copy of an agreement between Valve 

and , bearing Bates numbers 

VALVE_SYM_00001284-96. 

10. Attached as Exhibit 9 is a true and correct copy of Valve’s Responses and 

Objections to Plaintiff’s Venue Interrogatories, served on January 22, 2024. 

11. Attached as Exhibit 10 is a true and correct copy of an agreement between Valve 

and bearing Bates numbers VALVE_SYM_00001220-27. 

12. Attached as Exhibit 11 is a true and correct copy of the 

, 

bearing Bates numbers VALVE_SYM_00001122-37 

13. Attached as Exhibit 12 is a true and accurate depiction of the web page 

https://partner.steamgames.com/doc/sdk, captured on April 5, 2024. 

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14. Attached as Exhibit 13 is a true and correct copy of the Termination of Product 

Development Agreement between Valve, L.L.C. and Gearbox Software, L.L.C. terminating the 

Product Development Agreement dated August 21, 2001, bearing Bates numbers 

VALVE_SYM_00001178-88. 

15. Attached as Exhibit 14 is a true and accurate depiction of the web page 

https://store.steampowered.com/app/1286680/Tiny_Tinas_Wonderlands/, captured on April 5, 

2024.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 8, 2024

/s/ Kathleen R. Geyer

Kathleen R. Geyer

Case 2:23-cv-00419-JRG Document 60-2 Filed 04/15/24 Page 3 of 3 PageID #: 1488