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THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

SOCIAL POSITIONING INPUT 

SYSTEMS, LLC,

Plaintiff,

v.

VALVE CORPORATION,

Defendants.

 CIVIL ACTION NO. 2:23-cv-422-JRG

 JURY TRIAL DEMANDED

UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO 

DEFENDANT’S RULE 12(b)(3) MOTION TO DISMISS

Pursuant to Federal Rule of Civil Procedure (“Fed. R. Civ. P.”) 26(d)(1) and the Court’s 

Order allowing venue discovery in the Symbology case (see Symbology Innovations, LLC v. 

Valve Corporation, Case No. 2:23-cv-00419-JRG, Dkt. 24 (E.D. Tex. 2023), attached hereto as 

Exhibit A), Plaintiff Social Positioning Input Systems (“SPIS” or “Plaintiff) hereby moves for

leave to conduct limited, expedited venue discovery in this matter, and for an extension of time 

to respond to Defendant Valve Corporation’s (“Defendant” or “Valve”) Motion to Dismiss (Dkt. 

No. 11). Valve filed its Motion to Dismiss under 28 U.S.C. § 1406 and Fed. R. Civ. P. 12(b)(3)

on November 13, 2023. The parties dispute whether Valve has a regular and established place 

of business in this District and whether venue is proper in the Eastern District of Texas under

TC Heartland and In re Cray. The Parties have conferred, and Valve does not oppose the motion 

to conduct venue discovery consistent with the proposals outlined below. 

Furthermore, Valve moved to dismiss two other cases brought against it in this District 

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for improper venue under 28 U.S.C. § 1406 and Fed. R. Civ. P. 12(b)(3). See Symbology 

Innovations v. Valve Corp. et al., case No. 23-419 (E.D. Tex. Sept. 15, 2023); and Quantum 

Technology Innovations v. Valve Corp. et al., Case No. 23-425 (E.D. Tex. Sept. 18, 2023). 

Collectively, the three plaintiffs in these cases (Symbology, SPIS, and Quantum Technology 

Innovations) are owned in their entirety by Patent Asset management, LLC and are represented 

in their cases against Valve by the same undersigned counsel. Each of the venue allegations in 

the complaints filed by Symbology, Social Positioning Input Systems, and Quantum 

Technology Innovations are substantively identical, and Valve disputes that venue is proper in 

this District for any of the three cases.

Accordingly, to promote efficiency and conserve judicial resources, the parties hereby 

stipulate that the venue discovery order in the Symbology case (Case No. 23-419, Dkt. No. 24)

will be applied to all three cases. The parties further stipulate that the arguments made in Valve’s 

Motion to Dismiss in the first to proceed Symbology case (Case No. 23-419, Dkt. No. 11), 

Plaintiff’s Response, and any subsequent briefing be applied with equal force to all three cases.

Case 2:23-cv-00422-JRG-RSP Document 14 Filed 02/02/24 Page 2 of 4 PageID #: 131
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Dated: February 2, 2024 Respectfully Submitted,

/s/ Randall Garteiser

Christopher A. Honea

 Texas Bar No. 24059967

 chonea@ghiplaw.com

Randall Garteiser

 Texas Bar No. 24038912

 rgarteiser@ghiplaw.com

M. Scott Fuller

 Texas Bar No. 24036607

 rgarteiser@ghiplaw.com

GARTEISER HONEA, PLLC

119 W. Ferguson Street

Tyler, Texas 75702

Telephone: (903) 705-7420

Facsimile: (903) 405-3999

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

I HEREBY CERTIFY on this February 2, 2024, I caused to be electronically-filed the

foregoing document with the Clerk of Court using the Court’s CM/ECF system. As such, this 

document was served on all counsel who are deemed to have consented to electronic service.

/s/ Randall Garteiser

Randall Garteiser

CERTIFICATE OF GOOD FAITH

CONFERENCE

Pursuant to Eastern District of Texas Local Rule CV-7(i), counsel has complied with the 

meet and confer requirement in Local Rule CV-7(h). The Parties met and conferred on January 

22, 2024 by email to discuss the relief requested in this Motion. This motion is unopposed.

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/s/ Randall Garteiser

Randall Garteiser

Case 2:23-cv-00422-JRG-RSP Document 14 Filed 02/02/24 Page 4 of 4 PageID #: 133