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Unless I misunderstand you I suspect there is no way to do that in a straight Action.
Then again your description could be more comprehensive (screenshots might help) – how is the Folder defined, is it always the same folder, do you want a Folder selction dialog, what if more or less than three images are in the Folder …?
You could check the »Toggle dialog on/off«-field and manually select the files or you could use a small Script for the selection in the Action.
I have played with the >>Toggle dialogue on/off<< field and manually opened the files from their folder, but the action has the file's location written into it. I need it to open all files in a folder. As part of my Automator action, I am moving my photos (taken in batches of 3) into a workflow system of folders so the photos from the camera save to a "from camera" folder, and then move to a "for photoshop" folder, and those are the images that open into the ps action and get put into the template. The action saves the composite image to an archive folder, and deletes the image layers, and then the Automator action moves the originals to another archive folder. There shouldn't be issues as long as the actions keep running and I can figure out how to open files form a folder without referencing the specific images in the folder. Also please keep in mind that I am writing this as an action witihn Photoshop CS3, so basically clicking record, and letting the computer write the "code". Did that help?
Did that help?
Not really, I am not familiar with Automator.
Do you use a hotfolder-setup or start the process automatically?