Date: April 4, 2026 Purpose: Prove that KFU trust account deposits labeled "Retainer" were actually prepayments for specific fixed-fee patent services -- not retainers in the legal sense.
The trust ledger for KFU (Account 36372) labels 79.2% of incoming wire transfers ($9.66M of $12.20M) as "Wire Payment / Retainer." However, cross-referencing against three independent data sources proves these deposits were advance payments for itemized fixed-fee services, not retainers:
The word "Retainer" on the trust ledger is a bookkeeping label, not a description of the economic arrangement.
Cross-referencing the docket ledger PDFs (33110.90U and 33110.89U) with the invoice data reveals a standardized price list for patent services:
| Service | Fixed Fee | Components |
|---|---|---|
| Patent Application (standard) | $11,840 | $9,440 professional + $2,400 PTO filing |
| Patent Application (alternate) | $11,440 | $9,040 professional + $2,400 PTO filing |
| Patent Application (variant) | $11,040 | $8,640 professional + $2,400 PTO filing |
| Continuation Application (Suffix "A") | $3,440 | Professional fees for continuation filing |
Volume: 549 invoices at $11,440; 265 at $11,840; 28 at $11,040; 220 at $3,440
| Service | Fixed Fee | Components |
|---|---|---|
| Office Action Response | $1,600 | Attorney review + response drafting |
| IDS Filing / Restriction Response | $640 | Filing information disclosure statement |
| Issue Fee Payment | $920 | $440 professional + $480 PTO issue fee |
| Issue Fee + IDS combo | $784 | $240 professional + $544 PTO fees |
| Patent Office Review (allowance) | $2,400 | $3,000 minus 20% discount |
| Office Action + IDS combo | $1,160 | Combined response package |
| Complex Office Action Response | $1,400 | Higher-complexity matters |
Volume: 584 at $920; 271 at $1,600; 201 at $640; 104 at $784; 64 at $1,160; 38 at $1,400
| Service | Fixed Fee | Docket Suffix |
|---|---|---|
| Patent Search (current rate) | $400 | "S" (1,096 invoices at this price) |
| Patent Search (older rate) | $500 | "S" (284 invoices) |
| Maintenance Fee Payment | $865 | "U" (45 invoices) |
| Certificate of Correction | $360 | $200 professional + $160 PTO fee |
Stage 1: Trust Deposit Labeled "Retainer" - 6/19/2023: Transfer from Trust 36372 = $11,440 labeled "Patent Application 405690"
Stage 2: Hourly Time Tracked Internally - JBG (Goldberg): 10.30 hrs @ $495/hr = $5,098.50 - JNL (Long): 3.90 hrs @ $300/hr = $1,170.00 - FC (staff): 11.60 hrs @ $260/hr = $3,040.00 - LMD (drafter): 5.05 hrs @ $300/hr = $1,515.00 - HJ (staff): 0.30 hrs @ $65/hr = $19.50 - AS (staff): 0.20 hrs @ $65/hr = $13.00 - Total hourly value: ~$10,856 (but not what client pays)
Stage 3: Flat Fee Conversion (7/3/2024) All hourly entries zeroed out with explicit "Flat Fee" credit entries:
FEE: JNL -$420.00 Flat Fee
FEE: JBG -$346.50 Flat Fee
FEE: AS -$13.00 Flat Fee
FEE: LMD -$1,515.00 Flat Fee
FEE: HJ -$19.50 Flat Fee
Stage 4: Fixed-Fee Invoices Issued - Invoice 420646: $2,400 = "Patent Office Review" ($3,000 - 20% discount) - Invoice 420647: $920 = Issue Fee ($440 + $480 PTO) - Wire received 10/9/2024: $2,400 + $920 = $3,320 (exact match)
Both dockets show the identical pattern: internal hourly tracking reversed with "Flat Fee" labels, then replaced by standardized fixed-fee invoices.
| Date | Wire Amount | Label | Actual Use |
|---|---|---|---|
| 9/6/2022 | $265,715.42 | "Wire Payment / Retainer 36372" | Allocated to specific invoices |
| 11/23/2022 | $297,603.83 | "Wire Payment / Retainer" | Allocated to specific invoices |
| 11/23/2022 | $248,815.91 | "Wire Payment / Retainer" | Allocated to specific invoices |
| 12/23/2022 | $260,014.82 | "Wire Payment / Retainer" | Allocated to specific invoices |
| 1/18/2023 | $143,796.29 | "Wire Payment / Retainer" | Allocated to specific invoices |
| 1/31/2023 | $90,997.52 | "Retainer / Payment" | Allocated to specific invoices |
| 2/7/2023 | $42,804.19 | "Wire Retainer" | Allocated to specific invoices |
| 3/9/2023 | $331,322.00 | "Wire Payment / Retainer" | Allocated to specific invoices |
| 5/10/2023 | $936,422.00 | "Wire Payment/Retainer Multiple invoices" | Lists explicit invoice batches |
| 6/15/2023 | $523,144.00 | "Wire Retainer Multiple Dockets" | Allocated to 39+ dockets |
| 7/7/2023 | $296,898.00 | "Wire Retainer Multiple Dockets" | Allocated to specific dockets |
| 7/10/2023 | $331,352.00 | "Wire Retainer Multiple Dockets KFU" | Allocated to specific dockets |
| ... | ... | ... | ... |
| Total | $9,661,703.98 | All labeled "Retainer" | All allocated to fixed-fee invoices |
The trust ledger shows that upon receipt of each wire, Martha Long (JNL) immediately transferred funds to individual docket sub-accounts with specific service labels. For example, the 6/15/2023 and 6/19/2023 entries show simultaneous transfers to:
Each transfer names a docket number and service type. Nothing is held as a general retainer.
| Fixed Fee | Count | % of Total | Service Type |
|---|---|---|---|
| $400 | 1,096 | 22.6% | Patent Search |
| $2,400 | 718 | 14.8% | Patent Office Review / Filing Fee |
| $920 | 584 | 12.0% | Issue Fee Payment |
| $500 | 284 | 5.8% | Patent Search (older rate) |
| $11,440 | 284 | 5.8% | Patent Application (alt) |
| $1,600 | 271 | 5.6% | Office Action Response |
| $11,840 | 265 | 5.5% | Patent Application (std) |
| $3,440 | 220 | 4.5% | Continuation Application |
| $640 | 201 | 4.1% | IDS / Restriction Response |
| $784 | 104 | 2.1% | Issue Fee + IDS combo |
| $1,160 | 64 | 1.3% | Office Action + IDS combo |
| $865 | 45 | 0.9% | Maintenance Fee Payment |
| $9,440 | 41 | 0.8% | Application Professional Fees |
| $1,400 | 38 | 0.8% | Complex Office Action Response |
| $2,100 | 33 | 0.7% | Partial Continuation |
| Subtotal | 4,248 | 87.4% |
"Wire Payment / Retainer King Faisal University 36372"
"Flat Fee" (on every reversed hourly entry before rebilling at the fixed rate)
| Suffix | Meaning | Primary Fee | Invoice Count |
|---|---|---|---|
| U | Utility Patent Application | $11,440 or $11,840 | 2,574 |
| S | Patent Search | $400 or $500 | 1,419 |
| A | Continuation Application | $3,440 | 662 |
| G | General/Administrative | Varies ($25-$625) | 57 |
| X | PCT/International | $5,040 | 29 |
| D | Design Patent | Varies | 3 |
Every dollar flowing through Trust 36372 was earned through specific patent services performed under Litman's name. The "Retainer" label is irrelevant -- the underlying invoices prove fixed-fee-per-service billing where each service required use of Litman's name (POA, filing receipt, correspondence).
If these were retainer payments for discretionary services, one might argue Litman's name was incidental. But fixed-fee-per-patent billing proves each use of Litman's name was directly tied to a revenue event -- a commercial transaction, not a courtesy.
Each $11,840 patent application, each $2,400 patent office review, each $920 issue fee payment represents a discrete commercial transaction in which Litman's name and identity were the essential credential enabling the work. The trust ledger proves $12.2 million in KFU revenue alone flowed through this arrangement.
| Source | Path | What It Proves |
|---|---|---|
| KFU Receivables | evidence/gmail_downloads_account2/attachments/KFU_Receivables_Payments_061125.csv |
4,860 invoices with standardized BILLED amounts |
| Middle East Statements | output/MIDDLE_EAST_STATEMENTS_20250224.csv |
563 KFU invoices with fees/disbursement breakdown |
| Trust Ledger 36372 | output/KFU_TRUST_LEDGER_36372.csv |
Wire deposits labeled "Retainer," allocated to fixed-fee dockets |
| Docket Ledger 33110.90U | ~/Downloads/06.09.2025 33110.90U Ledger.pdf |
Full patent lifecycle: hourly tracking reversed as "Flat Fee" |
| Docket Ledger 33110.89U | ~/Downloads/06.06.2025 Docket No. 33110.89U Ledger.pdf |
Same flat-fee pattern with Certificate of Correction |
Analysis prepared from NGM's own accounting records produced in discovery.