Valve Corporation, V. Bucher Law, Pllc Et Ano

CourtCourt of Appeals of Washington
DecidedJune 30, 2025
Docket86585-4
StatusPublished

This text of Valve Corporation, V. Bucher Law, Pllc Et Ano (Valve Corporation, V. Bucher Law, Pllc Et Ano) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Valve Corporation, V. Bucher Law, Pllc Et Ano, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

VALVE CORPORATION, No. 86585-4-I

Respondent, DIVISION ONE

v. PUBLISHED OPINION

BUCHER LAW PLLC and AFN LAW, PLLC, and JOHN DOE CORPORATION,

Appellants.

FELDMAN, J. — It has long been recognized “that lawyers are officers of the

court who perform a fundamental role in the administration of justice.” Spevack v.

Klein, 385 U.S. 511, 524, 87 S. Ct. 625, 17 L. Ed. 2d 574 (1967). The litigation

privilege recognizes this fundamental role by affording attorneys immunity from

civil liability for communications that “have some relation to” a judicial proceeding

or a party to the proceeding. Deatherage v. Examining Bd. of Psychology, 134

Wn.2d 131, 135, 948 P.2d 828 (1997) (citing Restatement (Second) of Torts § 588

(AM. LAW INST. 1977)). The Uniform Public Expression Protection Act, chapter

4.105 RCW (UPEPA), augments this protection by providing “an expedited

process for dismissing lawsuits that target activities protected by the First

Amendment, such as freedom of speech, press, assembly, petition, and No. 86585-4-I

association on matters of public concern.” M.G. v. Bainbridge Island Sch. Dist.

#303, __ Wn. 3d ___, 566 P.3d 132, 144 (2025).

Contrary to these bedrock legal principles, Valve Corporation asserted

tortious interference and abuse of process claims against Bucher Law PLLC and

AFN Law PLLC (the Bucher Defendants) arising out of communications and

related conduct in the course of the law firms’ representation of thousands of Valve

customers who allege that its anticompetitive practices have raised prices for

computer games on its “Steam” platform and kept them at artificially high prices.

Because the litigation privilege indisputably protects the Bucher Defendants’

conduct, Valve’s claims fail as a matter of law and the trial court erred in denying

the Bucher Defendants’ motion to dismiss the claims under UPEPA. Accordingly,

we reverse and remand for entry of an order dismissing Valve’s claims against the

Bucher Defendants with prejudice.

I

Valve operates an online service known as “Steam.” Steam is a platform

through which video game developers sell and distribute games and Steam users

may purchase, download, and play those games.

Steam users agree to the Steam Subscriber Agreement (SSA), which

includes dispute resolution provisions. Addressing that issue, the SSA states, “If

Valve is unable to resolve your concerns and a dispute remains between you and

Valve . . . YOU AND VALVE AGREE TO RESOLVE ALL DISPUTES AND CLAIMS

BETWEEN US IN INDIVIDUAL BINDING ARBITRATION.” The SSA continues:

Try to Resolve Dispute Informally First . . . You and Valve agree to make reasonable, good faith efforts to informally resolve any dispute

2 No. 86585-4-I

before initiating arbitration. A party who intends to seek arbitration must first send the other a written notice that describes the nature and basis of the claim or dispute and sets forth the relief sought. If you and Valve do not reach an agreement to resolve that claim or dispute within thirty (30) calendar days after the notice is received, you or Valve may commence an arbitration. Written notice to Valve must be sent via postal mail . . . .

Thus, if a Steam user has a concern, claim, or dispute that the parties are unable

to resolve informally within thirty days, the user may commence an arbitration. The

SSA further states:

If you seek $10,000 or less, Valve agrees to promptly reimburse your filing fee and your share if any of AAA’s arbitration costs, including arbitrator compensation, unless the arbitrator determines your claims are frivolous or were filed for harassment. Valve agrees not to seek its attorneys’ fees or costs unless the arbitrator determines your claims are frivolous or were filed for harassment.

Critical here, the SSA prohibits Steam users from bringing or participating in a

class, collective, or representative arbitration and mandates “individual binding

arbitration only.”

The Bucher Defendants represent thousands of individual Steam users

seeking resolution in arbitration of disputes relating to Valve’s alleged

anticompetitive practices under federal antitrust and state consumer protection

laws. In accordance with the SSA, the Bucher Defendants initiated the dispute

resolution process by sending a letter on behalf of their clients relating to Valve’s

alleged anticompetitive practices and proposing settlement terms pursuant to the

informal dispute resolution process.

Valve responded that the notice lacked important customer identifying

information, was not particularized to individual customers, and “was not sent in

good faith.” The Bucher Defendants replied by sending Valve individual e-mails

3 No. 86585-4-I

on behalf of each of their clients following Valve’s request for individual complaints.

After the parties failed to resolve their disputes within the thirty-day window

established in the SSA, the Bucher Defendants filed their clients’ claims

individually in arbitration.

Following the initiation of the individual arbitration claims, Valve filed tortious

interference and abuse of process claims alleging that the Bucher Defendants had

attempted to “weaponize the terms of Valve’s dispute resolution agreement with

Steam users to line their own pockets” and that the Bucher Defendants “have

abused the legal process and interfered with Valve’s relationships with its

customers.” The Bucher Defendants then filed a dispositive motion, seeking

dismissal under UPEPA, CR 12, and CR 56.

The trial court denied the Bucher Defendants’ motion, holding (a) Valve has

alleged sufficient facts to establish plausible claims for tortious interference and

abuse of process, (b) the Bucher Defendants had failed to establish the litigation

privilege precluded Valve’s claims, and (c) “a statutory exception to UPEPA”

applied to the Bucher Defendants’ actions. Lastly, the court denied Valve’s request

for an award of attorney fees and costs under RCW 4.105.090 because the Bucher

Defendants had not filed their UPEPA motion with intent to delay the proceeding

and there was “at least some justification” for filing the motion. This timely appeal

followed.

4 No. 86585-4-I

II

A

Preliminarily, Valve argues the trial court’s UPEPA order is not appealable

as of right. We disagree.

RAP 2.2(a) limits appeals as of right to specified categories “[u]nless

otherwise . . . provided by statute . . . .” Here, UPEPA provides that a “moving

party may appeal as a matter of right from an order denying” a UPEPA motion.

RCW 4.105.080. Our Supreme Court recently confirmed, “A moving party may

appeal as a matter of right from an order denying a motion under RCW 4.105.020.”

Thurman v. Cowles Co., 4 Wn. 3d 291, 299, 562 P.3d 777 (2025). Based on these

legal authorities, we reject Valve’s argument that the trial court’s UPEPA order is

not appealable as of right. 1

B

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