SOL Patent Financial Analysis

Litman v. Goldberg, Index No. 524343/2025
Prepared March 26, 2026
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT

1. Payment Detail for All 16 SOL-Window Patents (Issued After 7/21/2024)

Each patent below was issued with "Richard C. Litman" on Line 74 (attorney of record) after the statute of limitations safe date. These are fixed-fee matters, not hourly — $15,000–$20,000 per patent is the standard range, plus USPTO government fees (hard costs).

#PatentClientDocketIssue DateTotal PaidHard CostsNet FeesPayment Date(s)Invoice(s)
112,043,608KFU33120.91U7/23/2024$17,400$2,880$14,52010/9/2024408711, 420480
212,043,609KFU33130.47U7/23/2024$15,800$2,880$12,92010/24/2023, 10/9/2024406416, 420108
312,049,459KFU33120.88U7/30/2024$15,160$2,880$12,28010/9/2024408567, 408583
412,054,460KFU33170.94A8/6/2024$5,000$2,880$2,12011/8/2024420326, 420198
512,054,464KFU33175.68A8/6/2024$3,480$3,040$4406/3/2024, 11/20/2024408027, 420199
612,062,780KFU33160.59U8/13/2024$12,760$2,880$9,8802/29/2024, 11/8/2024407556, 408864
712,065,424KFU33175.60A8/20/2024$3,480$3,040$4406/20/2024, 11/20/2024407985, 420195
812,071,437KFU33150.41U8/27/2024$13,000$2,880$10,1203/8/2024, 11/8/2024407514, 421003
9D1,046,141KSU33056.3810/8/2024$1,986$1,136$85010/21/2024408923
1012,114,620KISR32366.97U10/15/2024$1,030$480$5506/24/2024408965
1112,116,333KFU33150.71A10/15/2024$8,360$2,880$5,48011/8/2024421024, 421026
1212,157,086SACGC33060.73U12/3/2024$23,490$9,005$14,4851/11/2024, 2/14/2025405181, 421553
1312,194,434KSU33056.80A1/14/2025$5,730$2,880$2,85010/21/2024420188, 408719
1412,227,748KSU33056.75U2/18/2025$17,800$2,400$15,4004/30/2024, 3/12/2025420066, 421334
1512,303,254KSU33115.39U5/20/2025$0$0$0NO PAYMENTS
1612,280,479SACGC33060.78U4/22/2025$19,960$6,160$13,8008/22/2024, 2/24/2025408925, 422138
TOTAL$164,436$48,301$116,135

Patent 12,303,254 (row 15, highlighted in red) has ZERO payments recorded anywhere in the 205,632-line payments file. This is a KSU patent invoiced at approximately $14,700 with no recorded payment — a gap that supports the understatement theory.

Fixed-Fee Context: These are not hourly matters. Each patent is billed at a flat fee by phase (search, application, prosecution, issuance). The $15,000–$20,000 range for a full utility patent is standard. Additional fees will accrue if the client pays maintenance fees through the firm in future years.

2. Where the $32 Million Came From: Client Breakdown

From NGM's own Payments file (205,632 line items, July 2023 – May 2025):

ClientTotal Payments% of All
King Faisal University (KFU)$9,958,81772.4%
King Saud University (KSU)$1,614,59911.7%
Kuwait University$497,4313.6%
United Arab Emirates University$422,8743.1%
SACGC$110,5730.8%
KISR$82,7950.6%
Sultan Qaboos University$60,8420.4%
IMSIU$53,5140.4%
Dasman Diabetes Institute$51,2160.4%
All other university/ME clients$4,8580.0%
University/ME Subtotal$12,857,51993.5%
All other clients$898,1986.5%
GRAND TOTAL (Payments file)$13,755,717100%
Key Finding: 93.5% of all revenue comes from university/Middle East clients that Richard Litman originated. KFU alone accounts for 72.4%. Every dollar was billed under "RL — Richard Litman" as originating attorney.

3. The $15 Million Discrepancy — Three Revenue Numbers, One Question

SourceDescriptionAmount
NGM Trust Report (Exhibit A, Deborah Schaefer)Total receipts across both trust accounts (t23 + t3)$32,708,669
NGM Payments FileTotal client payments applied (Jul 2023 – May 2025)$13,755,717
NGM Workup (Goldberg's accounting)"Period Billed Receipts"$16,506,605
NGM Workup"Receipts Minus Expenses"$12,012,259

What Each Number Means

$32.7M (Trust Report): Total money that flowed into trust accounts under Litman's name. This includes client retainer deposits, USPTO fee payments, foreign agent fee deposits, and invoice payments. This is the number from NGM's own system-generated bank account summary, produced by Deborah Schaefer on June 26, 2025.

$16.5M (Workup "Period Billed Receipts"): Only payments that were applied to specific invoices. Excludes trust deposits not yet applied to invoices.

$12.0M (Workup "Receipts Minus Expenses"): Billed receipts minus billed expenses (USPTO fees, foreign agent costs). This is the number Goldberg uses to calculate the 20%.

The 20% Calculation Under Each Method

MethodRevenue Base20% OwedPaidDifference
Goldberg's Workup ($12M base)$12,012,259$2,402,452$2,403,126($674) "overpaid"
Trust Report ($32.7M less expenses)$29,380,403$5,876,081$2,403,126$3,472,955 OWED
Critical Finding: Goldberg's Workup shows $0 in receipts for KFU and KSU in its Revenue sheet — yet these two clients account for $11.6 million (84%) of all payments in NGM's own Payments file. The Workup appears to use a billing-entry-based accounting method that systematically excludes the trust account activity where the vast majority of university client revenue flows.

4. Trust Account Clarification

The trust accounts are designated "RL — Richard Litman" as the responsible lawyer, but the money belongs to clients. The June 2025 Trust Listing shows:

ClientTrust Balance (June 2025)Responsible Lawyer
King Faisal University (KFU)$689,276RL
King Saud University (KSU)$264,077RL
UAEU$43,862RL
SACGC$43,621RL
KISR$14,091RL
Kuwait University$12,080RL
All other clients$144,237RL
TOTAL TRUST BALANCE$1,211,244RL

These are client funds deposited into NGM's trust accounts (Eagle Bank and Bank of America), categorized under "RL" as the originating attorney. Every trust transaction, disbursement, and transfer is processed under Litman's name. The $689K KFU balance represents retainers for pending patent applications — each of which will generate additional revenue when the work is completed.

5. What This Means for the Revenue Base Dispute

The Question for Discovery and Trial

The arbitration agreement's 20% formula — does it apply to:

Either way, the Workup's exclusion of $16.2M in documented trust receipts from its calculations — and its showing of $0 for KFU/KSU in the Revenue sheet despite $11.6M in actual payments — is evidence of either (1) a deliberately misleading accounting, or (2) an accounting method so flawed it cannot be relied upon.

6. Additional Red Flags in the Accounting

IssueDetail
Jan 2024 Payment Missing from WorkupThe master Litman Summary shows $132,637 paid in Jan 2024 (Net Due = $0). The Workup Payments sheet skips from 1/11/2024 ($22,960 — Dec 2023 residual) to 3/8/2024 ($163,314 — Feb 2024). A $132K payment simply vanished.
Sep 2024 Amount MismatchWorkup: $16,469.11. Verified Summary: $17,866.40. Neither matches.
Jan 2025 ShortfallPaid $20,834.04 vs. $20,843.04 due. Only month where payment doesn't match exactly. $9.00 short.
Missing Allocations (June 2025)KFU Inv #405667 ($9,440), KFU Inv #407698 ($11,040), Authentic Amish Inv #318064 ($1,040), Kan Cui Inv #332617 ($1,954) — all paid but not allocated to Litman's 20%. Goldberg admitted the gap: "If that is not happening, I need to figure out why."
Patent 12,303,254 — Zero PaymentsKSU patent issued 5/20/2025, invoiced ~$14,700, with absolutely no payment record in 205,632-line payments file.
All figures derived from NGM's own system-generated reports: Payments_0723-0525_bydate.csv (205,632 lines),
Trust Listing for RCL June 2025.pdf, NGM_Litman_Workup.xlsx (137,239 revenue lines),
and Exhibit A (Summary by Bank Account, produced by Deborah Schaefer, June 26, 2025).