1 

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

SYMBOLOGY INNOVATIONS, LLC,

Plaintiff,

v. 

VALVE CORPORATION, GEARBOX 

SOFTWARE, L.L.C.,

Defendants.

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

 JURY TRIAL DEMANDED

UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFF’S COMPLAINT

Defendant Gearbox Software, L.L.C. (“Gearbox”) and Plaintiff Symbology Innovations, 

LLC (“Symbology”), by and through their undersigned counsel, respectfully file this Unopposed 

Joint Motion for an Extension of Time for Gearbox to Move, Answer or Otherwise Respond to 

Symbology’s Third Amended Complaint filed on March 24, 2024. (Dkt. 52). The current deadline 

for Gearbox to answer the Third Amended Complaint is May 23, 2024. The parties have conferred 

via email and agreed to a thirty (30) day extension, making the new answer deadline June 22, 2024. 

This is the third request for an extension to answer the Third Amended Complaint. Good 

cause exists because Symbology and Gearbox have jointly filed a motion to sever and stay 

Symbology’s claims against Gearbox (Dkt. 65), and have responded to the Court’s request for 

clarification (Dkts. 71, 72). Extending Gearbox’s time to answer will preserve judicial resources 

while the joint motion remains pending before the Court. The requested extension has not been 

made for purposes of delay and should not disrupt the schedule in this case. 

Case 2:23-cv-00419-JRG Document 77 Filed 05/21/24 Page 1 of 3 PageID #: 1666
2 

Accordingly, the parties respectfully request the Court grant this unopposed motion and 

extend the deadline to move, answer or otherwise respond to the Third Amended Complaint up to 

and through June 22, 2024. A proposed order is attached. 

Dated: May 21, 2024 

/s/ Randall Garteiser

Randall Garteiser, TBN 24038912 

Email: rgarteiser@ghiplaw.com

Christopher A. Honea, TBN 24059967 

Email: chonea@ghiplaw.com 

M. Scott Fuller, TBN 24036607 

Email: sfuller@ghiplaw.com

GARTEISER HONEA, PLLC

119 W. Ferguson Street 

Tyler, Texas 75702 

Telephone: (903) 705-7420 

Facsimile: (903) 405-3999 

Attorneys for Plaintiff 

Symbology Innovations, LLC 

/s/ Jessica M. Kaempf

Michael J. Sacksteder, CSB No. 191605 

(Admitted to E.D. Tex.) 

Email: msacksteder@fenwick.com 

FENWICK & WEST LLP

555 California Street, 12th Floor 

San Francisco, CA 94104 

Tel: (415) 875-2300 

Geoffrey Miller, TBN 24094847 

Email: gmiller@fenwick.com

FENWICK & WEST LLP

902 Broadway, 18th Floor 

New York, NY 10010 

Telephone: (212) 921-2001

Jessica M. Kaempf (WSBN 51666) 

(Admitted to E.D. Tex.) 

Email: jkaempf@fenwick.com

FENWICK & WEST LLP

401 Union Street, 5th Floor 

Seattle, WA 98101 

Telephone: (206) 389-4510 

Attorneys for Defendant 

Gearbox Software, L.L.C.

Case 2:23-cv-00419-JRG Document 77 Filed 05/21/24 Page 2 of 3 PageID #: 1667
3 

CERTIFICATE OF CONFERENCE

 The undersigned hereby represents and confirms that a conference was conducted with 

opposing counsel prior to filing this Motion and counsel indicated their agreement with the relief 

requested herein.

Dated: May 21, 2024 

 /s/ Jessica M. Kaempf 

CERTIFICATE OF SERVICE

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

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.

Dated: May 21, 2024 

 /s/ Jessica M. Kaempf 

Case 2:23-cv-00419-JRG Document 77 Filed 05/21/24 Page 3 of 3 PageID #: 1668