Litman v. Goldberg, Index No. 524343/2025 — Kings County
The following timeline shows that NGM's misappropriation of Richard Litman's name was not incidental or inadvertent. It was the product of a multi-year, three-phase plan: first laying client-facing infrastructure under Litman's domain, then exploiting his name on USPTO filings while quietly rerouting revenue, and finally erasing the digital evidence the moment litigation became imminent. The temporal precision of these acts — measured in days, not years — is itself proof of intent and willfulness.
| Date | Act |
|---|---|
| 2017 | Combination Agreement / Amendment — Customer Numbers transferred to NGM; personal name NOT transferred |
| 2018–2019 | Nine institutional client aliases created on @4patent.com (kfu@, ksu@, sacgc@, ku@, uaeu@, kisr@, etc.) — client-facing infrastructure laid on Litman's domain |
| Date | Act |
|---|---|
| 6/15/2020 | Litman's purported "termination" / SOL cutoff |
| 6/15/2021 | Goldberg: "I will continue managing the firm as I have been" (from Brooklyn) |
| 7/6/2021 | Goldberg signs professional liability insurance application listing Litman as "Of Counsel" |
| 10/2022 – 6/2023 | Arbitration proceedings (McCammon Group) |
| 6/14/2023 | Arbitration decision — Goldberg argues agreement terminated 6/15/2020 |
| Jul–Sep 2023 | Payment Allocation Reports go missing (3-month gap immediately post-arbitration) |
| Oct 2023+ | Standalone monthly Payment Allocation Reports begin under new format |
| Oct–Dec 2023 | Assignment correspondent briefly shifts to "RICHARD C. LITMAN" personally (2 KFU filings) |
| 12/21/2023 | "Bombshell" — Goldberg signs BOTH the POA and the KFU assignment cover sheet on the same day (App 18/392,663) |
| 1/24/2024 | Van Giezen directive — "The Pad" daily revenue tracking spreadsheet rolled out firm-wide |
| 1/26/2024 | KFU 2024 engagement letter signed by Goldberg as "Co-Managing Partner" — does NOT mention Litman |
| 2023+ | Renumbering scheme accelerates — Litman's clients reassigned to alternate numbers bypassing Attorney 418 |
| 2024 onward | Assignment correspondent shifts to Goldberg personally |
| 1/14–1/21/2025 | ATTORNEY NAME SWITCHOVER on patent Line 74 (Litman → Goldberg) — 205 NGM patents thereafter list Goldberg |
| 1/17/2025 | Most recent Goldberg-signed POA still bearing Litman's customer numbers |
| Date | Act |
|---|---|
| May–Jun 2025 | Litman receives ZERO payments |
| 6/10/2025 | Litman demands removal from NGM website |
| 6/24/2025 | COBRA email: "There is no basis without my consent… And actionable" |
| 6/26/2025 | "That is the answer that gets you into litigation" / "I calculate seven figures owed" |
| 7/16/2025 | WHOIS record for 4patent.com updated (2 days before email elimination) |
| 7/17/2025 | Formal litigation threat |
| 7/18/2025 | Email accounts eliminated (litman@4patent.com, rlitman@nathlaw.com) — one day after threat |
| Jul–Sep 2025 | Payment reporting blackout (3 months — coincides exactly with email elimination) |
| 8/17/2025 | Omar Albannai: "East or west Richard is the best… you are unplaceable to me" |
| 9/5/2025 | Litman removed from NGM website entirely |
| 9/18/2025 | Lev Dvorkin: "I turned to your firm solely for the reason that Mr. Richard Litman works with you" |
| 10/2025 | Index No. 524343/2025 filed in Kings County |
The dates speak for themselves. Infrastructure built years before the SOL cutoff, name-use accelerating across the arbitration, the Line 74 switchover the instant Goldberg felt safe, and digital evidence destroyed within 24 hours of a litigation threat — this is not negligence. It is a coordinated, willful course of conduct entitling Plaintiff to enhanced statutory and exemplary damages under N.Y. Civil Rights Law § 51.
Underlying exhibits: POA_GOLDBERG_SIGNATURE_TABLE.md; POST_20250114_NGM_PATENTS.csv; RENUMBERED_CLIENTS_VS_ALIASES_CROSSREF.md; ICLOUD_PHOTOS_EVIDENCE_MEMO.md; GMAIL_EVIDENCE_MEMO_2026-04-02.md; MECHANISM_OF_LIABILITY_MEMO.md; GOLDBERG_PERSONAL_ACTIONS_CHRONOLOGY.md; Arbitration Award (6/14/2023); Professional Liability Insurance Application (7/6/2021); KFU 2024 Engagement Letter; 4patent.com WHOIS history; Wayback Machine captures of nathlaw.com (June–Sept 2025).