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Mechanism Of Liability Memo

Mechanism of Liability: How Goldberg Used Litman's Name

Case: Litman v. Goldberg, Index No. 524343/2025 (NY Sup. Ct., Kings County) Prepared: 2026-03-17 Purpose: Answer the lawyers' question: How did Goldberg do it? — Document the specific mechanism by which Goldberg's affirmative acts caused Litman's name to appear on official USPTO records, public patent documents, and external correspondence.


The Mechanism in Plain Terms

Every time a patent application is filed with the USPTO, the applicant must identify an attorney/agent of record and a customer number for official correspondence. The customer number controls who receives all USPTO mail (office actions, notices of allowance, issue notifications, etc.).

Customer Number 37833 is the correspondence address of Nath, Goldberg & Meyer (NGM).

The mechanism Goldberg used: 1. File or take over a pending application listing Richard C. Litman as attorney of record and CN-37833 as the correspondence address. 2. Sign a Power of Attorney (PTO/AIA/82A) designating CN-37833 — keeping Litman's name as the named attorney while ensuring all USPTO mail goes to NGM. 3. Sign any assignment cover sheets in the same capacity. 4. Let the prosecution run — USPTO issues Filing Receipts, Office Actions, Notices of Allowance, and ultimately the patent itself — all bearing Litman's name as attorney of record. 5. Pay the issue fee via PTO-85B (IFEE) — an additional affirmative act confirming NGM's ongoing control.

At every step, Litman's name was placed into a government record by Goldberg's act or by the natural operation of the USPTO system following Goldberg's act. Litman did not consent to, participate in, or benefit from any of this.


The Document Chain: Stage by Stage

The following traces the documentary chain for App 18/392,663 → Patent 11,980,937, the strongest single application in the record (Goldberg signed both a POA and an assignment cover sheet on the same day — Dec. 21, 2023).

Stage 1 — Filing / POA (Dec. 21, 2023)

Document: PTO/AIA/82A — Power of Attorney Transmittal Signatory: /Joshua B. Goldberg/, Reg. No. 44126 Customer Number designated: 37833 (Nath, Goldberg & Meyer) Attorney named: Richard C. Litman File: evidence/poa_pdfs/POA_11980937_18392663_2023-12-21.pdf Legal significance: This is Goldberg's personal, signed federal form designating CN-37833 as the official correspondence address while naming Litman as attorney. From this moment, all USPTO mail for this application went to NGM, and all USPTO records identified Litman as the attorney of record.

Also on Dec. 21, 2023: Document: Patent Assignment Cover Sheet (USPTO) Signatory: /Joshua B. Goldberg/ — correspondence email: jgoldberg@nathlaw.com Correspondent block shows: RICHARD C. LITMAN / NATH, GOLDBERG & MEYER Reel/Frame: 065933 / 0139 Legal significance: On the same day as the POA, Goldberg signed the assignment cover sheet that also listed Litman as the correspondent attorney. Two separate federal documents, same day, same application — both showing Litman's name used under Goldberg's signature.


Stage 2 — Filing Receipt (Feb. 8, 2024)

Document Code: APP.FILE.REC — Filing Receipt Direction: OUTGOING (from USPTO to CN-37833/NGM) File: evidence/mechanism_docs/APP_FILE_REC_11980937_2024-02-08_[id].pdf What it shows: The USPTO's official acknowledgment of the application, addressed to CN-37833 (NGM), listing Richard C. Litman as attorney of record and the official correspondent address as Nath, Goldberg & Meyer. Legal significance: This is the first official government document confirming that as far as the USPTO is concerned, Litman is the attorney on this case and NGM is where all mail goes. This document was created entirely as a result of Goldberg's Dec. 21 filing act.


Stage 3 — Track One Grant (Feb. 22, 2024)

Document Code: TRACK1.GRANT — Track One Prioritized Examination Granted Direction: OUTGOING (USPTO to CN-37833/NGM) File: evidence/mechanism_docs/TRACK1_GRANT_11980937_2024-02-22_[id].pdf What it shows: USPTO confirms accelerated examination, addressed to CN-37833/NGM, Litman as attorney of record. Legal significance: Another official document bearing Litman's name sent to NGM — the pattern of ongoing use continues with each stage of prosecution.

Note on Office Actions: App 18/392,663 went directly to allowance via Track One (no rejections). For applications that received office actions — e.g., App 18/242,465 (Patent 12,043,608, 74 documents in IFW) — there will be CTNF/CTFR documents showing Litman's name and NGM's address on substantive USPTO correspondence requiring a response. These are high-value documents: office actions require the attorney of record to respond, meaning Litman's name was attached to active prosecution work being handled by NGM.


Stage 4 — Notice of Allowance / PTOL-85 (Apr. 3–15, 2024)

Document Code: NOA — Notice of Allowance and Fees Due (PTOL-85) Direction: OUTGOING (USPTO to CN-37833/NGM) Files: evidence/mechanism_docs/NOA_11980937_2024-04-03_[id].pdf evidence/mechanism_docs/NOA_11980937_2024-04-15_[id].pdf What it shows: The PTOL-85 is the official government form that later becomes Line 74 of the issued patent. It lists: - Attorney/Agent and Firm Name: Richard C. Litman / Nath, Goldberg & Meyer - Correspondence address: CN-37833 Legal significance: This is the direct bridge between prosecution correspondence and the public patent face. The attorney name on the PTOL-85 is the attorney name that appears on the issued patent. Goldberg's POA on Dec. 21 caused Litman's name to appear here five months later.


Stage 5 — Issue Fee Payment / PTO-85B (Apr. 4, 2024)

Document Code: IFEE — Issue Fee Payment (PTO-85B) Direction: INCOMING (submitted by NGM/Goldberg to USPTO) File: evidence/ifw_ifee/[patent]_IFEE.pdf What it shows: NGM (acting under Goldberg's direction) submitted the PTO-85B to pay the issue fee. This is an affirmative submission to the USPTO that triggers the patent grant. It is signed/submitted under the authority designated by the POA (i.e., Goldberg's act in Stage 1 is the authority for this submission). Legal significance: Goldberg's organization made an affirmative filing — under Litman's name as attorney of record — to issue this patent. They chose to proceed.


Stage 6 — Issued Patent (May 14, 2024)

Document: US 11,980,937 B1 Line 74: "Nath, Goldberg & Meyer; Richard C. Litman" File: evidence/mechanism_docs/EGRANT_PDF_11980937_2024-05-14_[id].pdf What it shows: The final public record. Litman's name appears on the face of the issued United States patent as the attorney responsible for prosecution. Legal significance: This is the public harm — Litman's professional identity and USPTO registration are permanently attached to a patent he did not prosecute, in a public government database, as a direct result of Goldberg's chain of acts.


Why Office Actions Are Especially Important

When an office action (CTNF/CTFR) is issued, the USPTO sends it to the attorney of record (Litman) at the correspondent address (CN-37833/NGM). The attorney of record is then legally responsible for responding within a statutory deadline.

In applications with office actions (see e.g. App 18/242,465, Patent 12,043,608 with 74 IFW documents), Litman's name was attached to: - Rejections from the USPTO examiner - Deadlines for response - The substantive back-and-forth of patent prosecution

This means Goldberg was not merely allowing Litman's name to appear passively — he was actively prosecuting patent applications under Litman's name as attorney of record, conducting examination correspondence that Litman had no knowledge of and did not authorize.


Assignments: The Second Channel of Use

In addition to the prosecution channel (POA → filing receipt → office actions → NOA → patent), Goldberg used a second channel: patent assignments.

When an inventor assigns a patent to a company (e.g., KFU), the assignment cover sheet requires an attorney/correspondent. Goldberg signed assignment cover sheets listing: - Correspondent: RICHARD C. LITMAN / NATH, GOLDBERG & MEYER - Signatory: /Joshua B. Goldberg/, jgoldberg@nathlaw.com

These assignments are recorded in the USPTO Assignment Center and become permanent public records linking Litman's name to the transaction.

Application Assignment Date Signatory Litman Correspondent Reel/Frame
18/392,663 2023-12-21 J. Goldberg RICHARD C. LITMAN / NGM 065933/0139
18/383,448 2023-10-29 J. Goldberg RICHARD C. LITMAN / NGM 065379/0084
18/118,551 2023-03-07 N. Usman (NGM staff) RICHARD C. LITMAN / NGM (see UAEU tracker)

Summary: The Mechanism in Three Acts

Act What Goldberg Did What USPTO Did Result
1. Filed/Took Over Application Signed POA (82A) naming Litman as attorney, designating CN-37833 Recorded Litman as attorney of record; all mail → NGM Litman's name entered USPTO system; NGM controls
2. Prosecuted Under Litman's Name NGM received and responded to office actions under Litman's name Issued office actions, Track One grants, NOAs addressed to NGM/Litman Each government document bore Litman's name; prosecution happened without Litman
3. Issued the Patent NGM submitted IFEE (issue fee) to confirm issuance Issued patent with Litman on Line 74 Permanent public record: Litman's name on US patent he did not prosecute

Documents to Obtain / Download

The following documents are available via the USPTO API from the IFW JSON files already in the project. Run python scripts/download_mechanism_docs.py (requires USPTO_API_KEY) to download all of them automatically.

Code Description Evidence Value
APP.FILE.REC Filing Receipt Shows Litman as attorney + NGM address at filing
CTNF Non-Final Office Action Shows Litman's name on active prosecution rejections
CTFR Final Office Action Same — even stronger (deadline pressure)
NOA Notice of Allowance (PTOL-85) Direct bridge to patent Line 74
ISSUE.NTF Issue Notification Shows Litman name → final confirmation
TRACK1.GRANT Track One Grant Shows Litman on expedited track decisions
BIB Bibliographic Data Sheet Internal USPTO record confirming attorney/assignee

After downloading, review each Filing Receipt and any office actions for the phrase "Richard C. Litman" in the attorney/correspondent block. These should be highlighted and tabbed in the exhibit binder alongside the corresponding POA.


Deposition Questions Arising from the Mechanism

  1. For each application with a POA signed by Goldberg: "You designated CN-37833 on this form. At that time, did you have Richard Litman's permission to list him as attorney?"
  2. For applications with office actions: "Who at NGM drafted the response to this office action? Was Litman consulted? Did Litman review it?"
  3. "The Filing Receipt for App 18/392,663 lists Richard Litman as attorney of record. Did you inform Litman that his name was being used on this application?"
  4. "The issued patent US 11,980,937 lists Richard Litman on Line 74. Did you obtain Litman's consent before causing his name to appear there?"

Documents referenced above are either already downloaded (see evidence/poa_pdfs/) or available for download via python scripts/download_mechanism_docs.py.