Prepared: 2026-04-15 Source: EMAIL_METADATA_ND0002.csv (NGM-produced discovery), EMAIL_METADATA_ND0001.csv Finding Classification: MAJOR -- Establishes the continuous, daily commercial use of Litman's name in direct client communications that drove KFU's multi-million-dollar payment stream
Martha Long sent 535 "Daily Report for King Faisal University" emails between May 5, 2023 and February 13, 2025, containing a total of 13,860 individually itemized docket entries. Every single report was sent to kfu@4patent.com -- an email alias hosted on Litman's personal domain (4patent.com), administered by NGM's Microsoft 365 tenant. Every report carried the "NATH, GOLDBERG & MEYER" firm signature block. KFU contractually required 50 substantive reports per day and imposed $500-per-report penalties for shortfalls, with documented fines reaching $13,000 in a single day. These daily reports were the operational mechanism that kept KFU engaged and paying -- and they were sent through Litman's name infrastructure the entire time.
All 535 daily reports are post-SOL (6/15/2020). All 535 are post-arbitration (6/14/2023). 195 are post-SOL-safe (7/21/2024).
After February 13, 2025, the consolidated "Daily Report" format was replaced by individual docket-level emails; Martha sent an additional 548+ emails to kfu@4patent.com through at least June 17, 2025 -- continuing the same work product delivery under the same Litman-domain infrastructure.
Each daily report follows an identical template:
Subject: Daily Report for King Faisal University -- [Date]
NOTE: This message is being sent via WhatsApp.
This email is for our records.
Dear Prof. Hany:
I hope you are well.
Here is the list of work sent to the University today, [Date].
1. Docket XXXXX.XXX - [Work description]
2. Docket XXXXX.XXX - [Work description]
...
Regards,
Martha
Martha Long
Paralegal
NATH, GOLDBERG & MEYER
112 S. West Street | Alexandria, VA 22314
Tel: 703.486.1000 | Toll Free: 1.800.4.PATENT (1.800.472.8368)
Fax: 703.486.7000 | Toll Free: 1.888.4.PATENT (1.888.472.8368)
mlong@nathlaw.com
| Month | Reports | Month | Reports |
|---|---|---|---|
| 2023-05 | 23 | 2024-01 | 22 |
| 2023-06 | 26 | 2024-02 | 19 |
| 2023-07 | 21 | 2024-03 | 37 |
| 2023-08 | 22 | 2024-04 | 31 |
| 2023-09 | 20 | 2024-05 | 19 |
| 2023-10 | 23 | 2024-06 | 19 |
| 2023-11 | 22 | 2024-07 | 22 |
| 2023-12 | 23 | 2024-08 | 22 |
| 2024-09 | 32 | ||
| 2024-10 | 24 | ||
| 2024-11 | 35 | ||
| 2024-12 | 32 | ||
| 2025-01 | 29 | ||
| 2025-02 | 12 |
Total: 535 reports across 22 months
| Metric | Value |
|---|---|
| Total line items | 13,860 |
| Average items per report | 25.9 |
| Largest single report | 102 items (Nov 28-29, 2023) |
| Smallest reports | 2-3 items (late Jan/Feb 2025) |
Each line item is a discrete piece of patent work. Categories include: - Completed patent search -- new invention evaluated - New patent application/Response to comments on patent search -- application stage - Patent application filed -- submitted to USPTO - Office action notification / Final office action notification -- USPTO correspondence forwarded - Amendment drafted and filed -- responsive pleading at USPTO - Notice of Allowance -- patent approved - Issue fee paid -- patent proceeding to grant - Issue notification / eGrant of issued patent -- patent issued - Notice of abandonment -- patent abandoned - RCE drafted and filed -- continuation after rejection - Completed disclosure review -- pre-search invention evaluation - Reminder -- Instructions needed from the University -- follow-up
Every daily report was sent to kfu@4patent.com -- an email alias on Litman's personal domain 4patent.com. Per Finding #43 (DKIM records), 4patent.com email is administered by NGM's Microsoft 365 tenant (nathlaw.onmicrosoft.com). Per Finding #46, kfu@4patent.com had 19,701 emails across the corpus -- it is NGM's primary client communication channel for KFU.
The "Managing Patent Portfolios" document (Sept 1, 2021, C2051472_ND0000270434.msg) sent by Goldberg to Dr. Abdulrahman Al Lily (KFU Dean) and CC'd to Litman at rlitman@nathlaw.com explicitly identifies:
"Point of contact in the firm is Martha Long (mlong@nathlaw.com and kfu@4patent.com)"
This document also identifies the parties as:
"Intellectual Property Law Firm: NGM Representatives are Mr Richard Litman (rlitman@nathlaw.com) and Mr Joshua Goldberg (jgoldberg@nathlaw.com)."
Every daily report sent to kfu@4patent.com was thus sent through an address on a domain bearing Litman's name ("4patent" = Litman's personal brand), to a distribution list that Litman was formally identified as a party to.
Each daily report references dozens of docket numbers. The patent applications filed under those dockets all list "37833 / Richard C. Litman / Nath, Goldberg & Meyer / 112 S. West Street / Alexandria, VA 22314" in the USPTO correspondence block (verified across all 21 mapped patents, Finding #108). When KFU received a daily report stating "Docket 33155.09U - Patent application filed," the underlying USPTO filing receipt for that docket bore Litman's name.
All 535 reports carry the "NATH, GOLDBERG & MEYER" firm name in the signature block. Litman's name is embedded in the firm identity -- KFU's foundational relationship was with "Mr Richard Litman" as explicitly stated in the Managing Patent Portfolios document.
Per Finding #43, the entire 4patent.com domain -- through which all daily reports were delivered -- 301-redirects to nathlaw.com. DKIM records prove NGM's tenant controls the domain. WHOIS was updated July 16, 2025 (2 days before email elimination). The daily reports were sent through Litman's name infrastructure.
On October 10, 2024 (post-SOL-safe period), Litman emailed Goldberg from rlitman@nathlaw.com (Subject: "Re: NO REMINDER from KFU"):
"I would reach out and ask if they if they have any inquiries about particular matters. Could add to email something positive happening which will be shown on the daily report."
This proves Litman was actively directing the content of the daily reports 4+ years after the SOL cutoff and 16 months after arbitration. He knew exactly what the daily report was and was coaching Goldberg on what to include in it.
KFU imposed a contractual penalty of US$500 for each report below the daily quota of 50 substantive reports. This is not speculative -- it is documented across 22+ penalty-related emails in the corpus.
| Date | Penalty Demanded | Context |
|---|---|---|
| 2023-10-17 | $1,500 | "Imperative Compliance Measures and Deadlines" |
| 2023-11-02 | $6,000 | "62 reports required for current day" |
| 2023-11-03 | $2,500 | Deduction from invoice |
| 2023-11-10 | $5,000 + $5,000 | "POTENTIAL SUBSTANTIAL FINES" |
| 2023-11-26 | $10,000 | Message from KFU |
| 2023-11-27 | $5,000 | "Failure to meet adjusted quota of 75 reports" |
| 2023-11-29 | $13,000 | Martha: "I respectfully request that the University waive the penalty of $13,000.00" |
| 2023-12-05 | $3,000 | "PENALTY from KFU" |
| 2023-12-06 | $1,500 / $3,000 / $4,500 | Escalating penalties |
| 2023-12-14 | $4,000 | "Clarifications, Complaints and Penalties" |
| 2023-12-23 | $5,000 | "Work on Christmas Day -- Message from KFU" |
| 2024-03-27 | $5,500 - $12,000 | Multiple penalty notifications |
| 2024-04-03 | $12,000 | Two penalty notifications |
| 2024-04-04 | $13,000 | Penalty notification |
| 2024-04-09 | $11,500 | Penalty notification |
| 2024-12-16 | (amount TBD) | "Penalties for King Faisal University Invoices" |
From KFU Dean's Office to Martha/Goldberg:
"We request the submission of an additional 25 substantive reports today, Sunday, in addition to the standard daily quota of 50, totaling 75 reports. Failure to meet this adjusted quota will result in the enforcement of the stipulated penalty of US$5,000."
Martha's response to Goldberg:
"Thanks, Josh. I am 50 reports right now. I only have about 12 more -- so we are not going to make 75. What do you want me to do?"
The penalty regime proves: (a) KFU treated the daily reports as a contractual deliverable with financial consequences; (b) the volume was staggering -- 50 substantive reports per day; (c) NGM's revenue depended on meeting these quotas.
The following international money transfer credits from KFU are documented in email subject lines:
| Date | Amount | Notes |
|---|---|---|
| 2020-09-30 | $79,945.00 | Three incoming wires |
| 2022-12-22 | $260,014.82 | |
| 2023-01-17 | $143,796.29 | |
| 2023-01-30 | $90,997.52 | |
| 2023-02-06 | $42,804.19 | |
| 2023-03-08 | $331,322.00 | |
| 2023-05-09 | $936,422.00 | Largest single wire |
| 2023-06-14 | $523,144.00 | Day of arbitration decision |
| 2023-07-06 | $296,898.00 | |
| 2023-07-07 | $331,352.00 | |
| 2023-09-13 | $593,610.00 | |
| 2023-09-26 | $594,850.00 | |
| 2023-10-13 | $553,890.00 | |
| 2023-11-06 | $588,298.00 | |
| 2023-11-22 | $595,204.00 | |
| 2023-12-18 | $595,838.00 | |
| 2023-12-26 | $583,262.00 | |
| 2023-12-29 | $394,890.00 | |
| 2024-02-12 | $648,374.00 | |
| 2024-02-20 | $597,666.00 | |
| 2024-02-28 | $597,130.00 | |
| 2024-03-18 | $595,214.00 | |
| 2024-04-03 | $659,772.00 | |
| 2024-10-09 | $499,931.00 | |
| 2024-10-25 | $499,352.00 | |
| 2024-11-07 | $499,487.00 | |
| 2024-11-19 | $499,658.00 |
Visible KFU wires in corpus: ~$12.2M (deduplicated unique date+amount combinations)
The complete billing chain is documented in the corpus:
| Martha Invoice Date | KFU Wire Date | Wire Amount |
|---|---|---|
| 2023-09-25 | 2023-10-13 | $553,890.00 |
| 2023-10-25 | 2023-11-06 | $588,298.00 |
| 2023-11-17 | 2023-11-22 | $595,204.00 |
| 2023-12-01 | 2023-12-18 | $595,838.00 |
| 2023-12-19 | 2023-12-26 | $583,262.00 |
| 2024-02-07/14 | 2024-02-12/20/28 | $648K/$597K/$597K |
| 2024-03-12/28 | 2024-03-18/2024-04-03 | $595K/$659K |
| 2024-10-20 | 2024-10-09/25 | $499K/$499K |
| 2024-11-03/17 | 2024-11-07/19 | $499K/$499K |
The pattern is clear: Martha's daily reports and invoices drove KFU's payment cycle. The reports were the proof of work that justified the invoices, and the invoices triggered the wires.
After February 13, 2025, the consolidated "Daily Report" format stopped. Martha transitioned to individual docket-level emails to kfu@4patent.com:
Additionally, Karen Van Giezen began sending weekly "KFU Data" reports (KFU Issued and Allowed reports) to Martha and Goldberg, CC'd to kfu@4patent.com -- a new reporting layer introduced in 2025.
The daily report format changed, but the underlying pattern continued: Martha communicating KFU work product through Litman's domain infrastructure.
Goldberg was not a passive recipient. He actively participated in the daily report process:
From the penalty exchange (Nov 3, 2023), Goldberg defended against KFU's $2,500 penalty by arguing average weekly report counts:
"If KFU wants 50 reports a day, that is 250 per week. The first four days of this week, we sent 230 reports or 57.5 reports a day."
Goldberg knew exactly how many reports were being sent, knew the financial consequences of falling short, and personally managed the relationship -- all while Litman's name appeared on every filing receipt, every patent, and every email alias through which this communication flowed.
Under the deck-of-cards theory, each of the 535 daily reports constitutes a separate commercial use of Litman's name for purposes of NY Civil Rights Law Section 51. The reports were: - Sent through Litman's domain (kfu@4patent.com on 4patent.com) - For trade or commercial purposes (maintaining the KFU client relationship that generated $12M+ in visible wires) - Without Litman's consent (Litman never authorized post-termination use of his name in KFU communications)
The penalty regime proves the daily reports were not informational -- they were a contractual obligation directly tied to revenue. KFU deducted penalties from invoices. Missing reports meant lost revenue. The reports were the mechanism by which NGM demonstrated to KFU that work was being performed, which justified the invoices, which triggered the wire payments.
This is the concrete proof that Litman's name on the communications infrastructure directly drove KFU's continuous payment of millions.
Each line item in a daily report references a specific patent docket. Each of those dockets has: - A Filing Receipt with "Richard C. Litman" in the correspondence block (Finding #108) - A Power of Attorney filed with the USPTO - All subsequent Office Actions, Amendments, Notices of Allowance, and eGrants bearing Litman's name
The 13,860 line items are not 13,860 separate patents -- many dockets appear multiple times as they progress through the patent process. But they represent 13,860 separate instances where KFU was shown specific work product tied to dockets that bear Litman's name.
Litman's October 10, 2024 email proves he was actively directing the content of the daily reports:
"Could add to email something positive happening which will be shown on the daily report."
This destroys any argument that Litman was uninvolved or that the daily reports were an internal operational matter unrelated to his name use. He knew about them, directed them, and connected them to the client engagement strategy.
The billing chain documented above establishes:
Daily Report (via kfu@4patent.com) --> Invoice (via kfu@4patent.com) --> KFU Wire Payment ($400K-$660K/month) --> NGM Trust Account --> 20% Litman Fee-Credit (systematically undercredited)
Per Finding #51, $9.89M in KFU deposits were never allocated to Litman. Per Finding #60, KFU holds 574 U.S. patents, making it the #1 patent-granting university globally. Per Finding #61, 98% of all NGM matters were originated by Litman. The daily reports were the daily proof-of-work that sustained this entire revenue stream.
| Finding | Connection |
|---|---|
| #43 | 4patent.com DKIM proves NGM controls Litman's domain |
| #46 | kfu@4patent.com = 19,701 total emails in corpus |
| #47 | Litman directing daily report content Oct 10, 2024 |
| #51 | $9.89M KFU deposits unallocated / $1.98M unpaid |
| #52 | KFU in both domain-alias and renumbering overlays |
| #53 | Goldberg's June 11, 2025 written admission of KFU liability |
| #60 | KFU = #1 patent-granting university globally (574 patents) |
| #62 | Goldberg's written admission "invoice numbers not matching matter numbers" |
| #63 | 2,457 KFU dockets billed without matching invoice ($1.02M) |
| #66 | 20% rule validated across 21 months |
| #107 | CN-37833 name removal May 1, 2025 |
| #108 | All 21 filing receipts show "Richard C. Litman" |
| Metric | Value |
|---|---|
| Total "Daily Report" emails | 535 |
| Date range | May 5, 2023 -- Feb 13, 2025 |
| Total line items across all reports | 13,860 |
| Average items per report | 25.9 |
| Largest single report | 102 items |
| Reports addressed to "Prof. Hany" | 534/535 |
| Reports with WhatsApp parallel delivery | 532/535 |
| Reports with NGM firm signature | 535/535 |
| Reports sent to kfu@4patent.com | 531/535 (490 TO + 41 CC) |
| All reports post-SOL (6/15/2020) | 535/535 (100%) |
| All reports post-arbitration (6/14/2023) | 500/535 (93%) |
| Post-SOL-safe (7/21/2024) | 195/535 (36%) |
| KFU daily quota requirement | 50 substantive reports |
| Penalty per missing report | US$500 |
| Highest single-day penalty demanded | $13,000 |
| Post-daily-report individual emails (Feb-Jun 2025) | 548+ |
| Visible KFU wire payments in corpus | ~$12.2M |
| KFU invoices from Martha | 63 |
| Goldberg-authored daily report responses | 6 |
| Goldberg-forwarded daily reports | 35 |
This document supplements the existing evidence architecture. Each daily report is a concrete, dated, Bates-traceable instance of Litman's name being used in commercial communications that directly sustained the KFU revenue stream.