Three dogs in the snow.
Three dogs playing fetch.
Being in the snow does not necessarily imply they are playing.  Dogs can play in other ways than just playing fetch.
exists x1 x2.(n_snow(x2) & a_topic(x1) & in(x1,x2) & n_dog(x1) & card_eq_3(x1))
exists e2 e1 x1 x2.(Actor(e2,x1) & v_fetch(e2) & Actor(e1,x2) & v_play(e1) & (x1 = x2) & n_dog(x1) & card_eq_3(x1))