← litmanintelligence.com  |  ← Counsel PDFs index  |  Counsel dashboard

Federal Complaint Analysis

FEDERAL COMPLAINT ANALYSIS

Litman v. Nath & Associates, PLLC, 1:25-cv-04048 (PKC)(PK) (EDNY)

Third Amended Complaint -- Analysis for State Case Use

Prepared: 2026-04-02 Source Documents Reviewed: 1. Third Amended Complaint (FINAL VERSION) -- 27 pages + 4 exhibits 2. Letter for First Amended Complaint (Aug. 13, 2025) -- cover letter to Judge Kuo 3. Second Amended Complaint (SAC) -- state court filing (Kings County, Index No. 524343/2025)


I. CAUSES OF ACTION -- FEDERAL (Third Amended Complaint)

The federal complaint asserts four causes of action, all under the Lanham Act, 15 U.S.C. section 1125(a):

Count Claim Statute Theory
I False Endorsement 15 U.S.C. section 1125(a)(1)(A) Website listings ("Patent Attorney" / "Patent Attorney (Retired)") falsely suggested Litman endorsed or supervised NGM's services
II False Affiliation / False Association 15 U.S.C. section 1125(a)(1)(A) Public designations created misleading impression Litman maintained ongoing connection with NGM
III False Designation of Origin 15 U.S.C. section 1125(a)(1)(A) USPTO filings listing Litman as attorney of record falsely designated origin of legal services
IV False Advertising / Misrepresentation 15 U.S.C. section 1125(a)(1)(B) Website, Google-indexed pages, email signatures, and USPTO listings misrepresented the identity of the responsible practitioner

Note: The federal case was voluntarily dismissed. These causes of action were never adjudicated on the merits. The federal complaint's factual allegations, however, were made under penalty of perjury (Verification clause, p. 26) and constitute Litman's sworn factual account.


II. CAUSES OF ACTION -- STATE (Second Amended Complaint)

The SAC (state court) takes a different approach, focusing on: - Equitable accounting of vested purchase price payments - Constructive trust over misappropriated revenues - Damages for identity exploitation

The SAC specifically raises the $16 million revenue discrepancy and the accounting fraud theory -- claims not present in the federal complaint. The state case targets Goldberg individually; the federal case targeted NGM as entity.


III. KEY FACTUAL ALLEGATIONS (Third Amended Complaint)

A. The 2017 Sale -- Identity Was Never Transferred

B. The Nunc Pro Tunc Assignment (Exhibit R) -- Goldberg's Written Admission

C. Federal Regulations -- Identity Cannot Be Delegated

D. Post-Termination Misuse (2020-2025) -- Three Forms

Website (Para. 50-52): - Listed Litman as "PATENT ATTORNEY" for years after termination - After objection, changed to "PATENT ATTORNEY (RETIRED)" -- falsely suggesting he remained associated while merely retired - Exhibits B and C are website screenshots (text captured in PDF)

USPTO Filings (Para. 53-56): - Filed new applications listing Litman as attorney of record / correspondence attorney after 6/15/2020 - Each filing = false certification under 37 C.F.R. section 11.18(b) and false designation of origin under Lanham Act - Exhibit A contains "Representative USPTO Front Pages Showing Plaintiff Falsely Listed as Attorney of Record Post-June 14, 2023"

Client-Facing (Para. 57-59): - Continued referencing Litman's personal goodwill and reputation to retain Middle East institutional clients - Did so despite knowing Litman was no longer affiliated

E. Saudi Arabia / Middle East Client Relationships

F. "Senior Counsel" Was Transitional Only


IV. GOLDBERG/NGM ADMISSIONS AND STATEMENTS REFERENCED

  1. Exhibit R (Nunc Pro Tunc Assignment, May 2021): Goldberg signed a document expressly stating "Assignor retains ownership of his personal name, signature, likeness, image, and persona." This is the single most powerful admission in the entire case -- Goldberg's own signed writing destroys his consent defense.

  2. Arbitration Award (June 14, 2023): Determined Plaintiff's affiliation terminated effective June 15, 2020. Goldberg's own position was that the relationship ended retroactively on that date.

  3. "As if he had died" (SAC Para. 15): Goldberg's position in arbitration was that Litman's physical disability should be treated "as if he had died" with termination retroactive to 6/15/2020.

  4. Implicit Admission of Control (Para. 48-56): The complaint's structure establishes that NGM/Goldberg had sole control over what name appeared on USPTO filings and the website -- Litman "had no involvement and no knowledge of the filings."


V. DAMAGES SOUGHT (Federal)

The federal complaint seeks:

  1. Permanent injunction against all further use of Litman's name, identity, likeness, persona, professional biography, USPTO practitioner identity, registration number, signature authority, and attorney-of-record identity
  2. Corrective measures:
  3. Remove Litman's name from all websites, marketing materials, professional biographies
  4. File USPTO substitutions removing Litman as attorney of record on all pending applications
  5. Issue written corrective notices to all affected clients
  6. Post corrective statement on NGM's website
  7. Remove Litman's name from Google-indexed/cached/archived pages
  8. Disgorgement of all profits, revenues, fees, or commercial benefits derived from unauthorized use
  9. Actual damages (loss of control over identity, harm to goodwill, reputational injury, emotional distress) plus treble damages under 15 U.S.C. section 1117 for willful misconduct
  10. Attorneys' fees and costs under 15 U.S.C. section 1117(a) (exceptional case)
  11. Pre- and post-judgment interest
  12. Jury trial demanded

VI. STATE CASE (SAC) -- ADDITIONAL FACTUAL CLAIMS

The SAC contains factual claims NOT in the federal complaint:

  1. $16 million revenue discrepancy (Para. 16): "Upon information and belief, this shortfall is the result of large accounts receivable in the millions of dollars being written off at Defendant's direction, enabling those funds to be repurposed without crediting Plaintiff."
  2. $2 million KFU collection (Para. 15): Litman "personally interceded to collect approximately $2 million from University 1" -- Goldberg represented these as payment for aged receivables and claimed the firm had stopped work for the client.
  3. Disability = death theory (Para. 15): Goldberg's position was that Litman's disability should be treated "as if he had died" -- while simultaneously using his name as if he were alive and active.
  4. New accounting system (Para. 2): Goldberg "transitioned to a new accounting system that erased or misclassified revenues tied to Plaintiff's originated clients, reclassified millions as 'retainers,' booked phantom payments, and concealed historical data."
  5. Health insurance as leverage (Para. 3): Defendant continued "keeping him on health insurance" as part of the scheme to maintain the appearance of affiliation.
  6. "Dead/Alive" contradiction (Para. 4): "Defendant's contradictory conduct -- treating Plaintiff as 'dead' to cut off payments while treating him as 'alive' to profit from his name and goodwill -- is inequitable."
  7. Seal request by Goldberg: SAC notes Goldberg took the position that accounting records and client data should be held under seal.

VII. EXHIBITS ATTACHED TO FEDERAL COMPLAINT

Exhibit Description Evidence We Already Have?
A Representative USPTO Front Pages (Post-6/14/2023) -- 6 patents YES -- we have 12 annotated patent front pages, 905-patent dataset, and post-switchover analysis
B Website screenshot: "PATENT ATTORNEY" listing YES -- we have nathlaw.com website screenshots from Wayback Machine
C Website screenshot: "PATENT ATTORNEY (RETIRED)" listing YES -- we have this screenshot
R 2021 Trademark Assignment Nunc Pro Tunc YES -- this is the Nunc Pro Tunc Assignment at Reel 007281, Frame 0821 that we have documented extensively

VIII. CROSS-REFERENCES TO EXISTING EVIDENCE

Already Documented and Corroborated

Federal Complaint Allegation Our Evidence
Litman listed as attorney on patents post-6/15/2020 905-patent dataset; 206 outgoing USPTO documents identified
Goldberg signed POAs causing Litman's name to appear 16 of 21 POAs with Goldberg's signature confirmed via OCR
Nunc Pro Tunc Assignment reserves Litman's identity Assignment at Reel 007281, Frame 0821; documented in MECHANISM_OF_LIABILITY_MEMO.md
Website listing as "Patent Attorney" Wayback Machine screenshots through June 21, 2025
Website listing as "Patent Attorney (Retired)" Wayback Machine screenshot
Website removal by Sept 2025 Sept 5, 2025 screenshot shows Litman removed entirely
King Faisal University / King Saud University clients KFU = 467+ patents; KSU = 2 new patents (12,227,748 and 12,303,254)
Arbitration award terminating affiliation 6/15/2020 Award obtained 03/27/2026
"As if he had died" argument Documented in RESEARCH_LOG and text message thread
Post-termination USPTO filings 21 IFW JSON files from USPTO API confirming filing chain
Jan 2025 attorney name switchover Litman to Goldberg between Jan 14-21, 2025; 205 post-switchover patents
$16M accounting gap Documented: $32.7M trust vs. $16.5M workup
Health insurance leverage Cheryl's Crohn's disease; documented in text messages
Client drawn by Litman's name Thomas Bennington (July 3, 2025): "a customer of Richard Litman's from way back"
Personal goodwill with clients Omar Albannai (Aug 17, 2025): "East or west Richard is the best"

Goldberg's Answer Admissions That Corroborate Federal Allegations

Per Doc #65 (Jan. 20, 2026 Answer in state case): - ADMITS Litman's name appeared on patent front pages (Para. 32) - ADMITS Litman's name appeared on NGM website after 6/15/2020 (Para. 72) - DENIES he "caused" name to appear (Para. 33) -- contradicted by 16 POA signatures


IX. NEW FACTS OR CLAIMS NOT PREVIOUSLY CATALOGED

From the Third Amended Complaint:

  1. "Nephew of the King of Saudi Arabia" invitation (Para. 10, 64): Litman states he was "personally invited by the nephew of the King of Saudi Arabia to support the Kingdom's innovation initiative." This specific royal connection has not been separately documented in our evidence corpus. It strengthens the personal goodwill argument -- these were not generic client relationships but ones flowing from Litman's personal status.

  2. Google-indexed pages claim (Para. 96): The federal complaint specifically alleges Google-indexed pages and email signatures as additional channels of false representation, beyond the website and USPTO. Google indexing creates additional "publications" for section 51 purposes in the state case.

  3. "Each instance... a separate violation" (Para. 62): Litman explicitly argued in federal court that "Each instance of Defendant's commercial use of Plaintiff's identity constitutes a separate violation" -- this mirrors and supports our "deck of cards" theory for the state case (each USPTO document = separate section 51 use).

  4. Federal regulatory void argument (Para. 41-46): The complaint argues that even if consent existed, it would be void as a matter of federal law because 37 C.F.R. prohibits delegation of practitioner identity. This argument -- that consent is legally impossible for USPTO identity -- has not been fully developed in our state case materials. It could be deployed to defeat Goldberg's Affirmative Defense #10 (consent) on pure legal grounds.

  5. Five service marks transferred (Para. 27): The Nunc Pro Tunc Assignment identified only 5 service marks that were transferred. "Richard C. Litman" was not among them; only corporate marks like "Litman Law Offices, Ltd." were conveyed. This specificity strengthens the "what is not assigned is retained" argument.

From the SAC:

  1. New accounting system allegation (Para. 2): Goldberg "transitioned to a new accounting system that erased or misclassified revenues tied to Plaintiff's originated clients, reclassified millions as 'retainers,' booked phantom payments, and concealed historical data." This is more specific than what we have documented about the accounting fraud.

  2. $2M KFU collection by Litman personally (Para. 15): Litman "personally interceded to collect approximately $2 million from University 1" -- and Goldberg claimed the firm had "stopped work for the client." This contradicts the disability=death theory (if Litman was "dead" to the firm, why was he collecting from clients?).

From the Letter for FAC:

  1. Filing timeline: The First Amended Complaint was filed August 13, 2025 as of right under FRCP 15(a)(1)(B). Attorney for Goldberg identified as Leo J. Hurley, Jr., Esq. This confirms the federal case was active at least through August 2025.

1. Judicial Estoppel (Strongest Use)

The federal complaint, verified under penalty of perjury, contains Litman's sworn account of the facts. More importantly, Goldberg's positions in the federal case (via his counsel's filings and the sanctions brief) contain admissions. The voluntary dismissal does not erase statements made during the litigation. Any position Goldberg took in the federal case that contradicts his state court defenses is subject to judicial estoppel.

Specific application: If Goldberg argued in the federal case that the agreement authorized name use (to defeat Lanham Act claims), he cannot argue in state court that there was no "use" or that it was merely incidental.

The federal complaint's treatment of Exhibit R (Para. 25-33) provides a ready-made legal framework for defeating Affirmative Defense #10 (consent) in the state MSJ: - Goldberg signed a document expressly reserving Litman's identity rights - The document is the "only written instrument addressing identity rights" - "What is not assigned is retained" - "Consent cannot be implied where a written contract expressly reserves rights"

3. "Each Instance = Separate Violation" Precedent

Para. 62's formulation ("Each instance of Defendant's commercial use of Plaintiff's identity constitutes a separate violation") was Litman's position in federal court. This directly supports the "deck of cards" theory in the state case -- each of the 206 outgoing USPTO documents is a separate section 51 "publication."

The argument at Para. 36-46 (USPTO identity is non-delegable under federal law) provides an independent basis to defeat the consent defense: even if Litman had consented, such consent would be void as against federal regulatory policy. This argument has not yet been fully deployed in the state MSJ materials.

5. "Dead/Alive" Contradiction for Willfulness

The SAC's framing (Para. 4) -- "treating Plaintiff as 'dead' to cut off payments while treating him as 'alive' to profit from his name" -- is a powerful rhetorical frame for willfulness in the state case. Goldberg cannot have it both ways.

6. Verified Factual Admissions by Litman

Because the Third Amended Complaint was verified under penalty of perjury, Litman's own factual allegations are admissible as his sworn statements. Key ones to cite: - Para. 1: Sale transferred practice but not identity - Para. 7: Goldberg's written admission in Exhibit R - Para. 21: Litman performed no substantive legal work after the sale - Para. 53-55: Litman had "no knowledge of and no involvement in" the post-termination filings


XI. KEY DIFFERENCES: FEDERAL vs. STATE CASE

Feature Federal (EDNY) State (Kings County)
Defendant NGM (entity) Goldberg (individual)
Cause of action Lanham Act section 43(a) -- 4 counts NY Civil Rights Law sections 50-51 (Count V only survives)
Identity theory False endorsement, false origin, false advertising Misappropriation of name for commercial purposes
Damages theory Disgorgement + treble damages + attorney's fees Actual damages + potentially punitive
Accounting claims Not included $16M discrepancy, constructive trust, equitable accounting
Status Voluntarily dismissed Active -- BOPs due 04/02/2026
Verification Under penalty of perjury Standard pleading

XII. DOCUMENT LOCATIONS