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).
| # | Patent | Client | Docket | Issue Date | Total Paid | Hard Costs | Net Fees | Payment Date(s) | Invoice(s) |
|---|---|---|---|---|---|---|---|---|---|
| 1 | 12,043,608 | KFU | 33120.91U | 7/23/2024 | $17,400 | $2,880 | $14,520 | 10/9/2024 | 408711, 420480 |
| 2 | 12,043,609 | KFU | 33130.47U | 7/23/2024 | $15,800 | $2,880 | $12,920 | 10/24/2023, 10/9/2024 | 406416, 420108 |
| 3 | 12,049,459 | KFU | 33120.88U | 7/30/2024 | $15,160 | $2,880 | $12,280 | 10/9/2024 | 408567, 408583 |
| 4 | 12,054,460 | KFU | 33170.94A | 8/6/2024 | $5,000 | $2,880 | $2,120 | 11/8/2024 | 420326, 420198 |
| 5 | 12,054,464 | KFU | 33175.68A | 8/6/2024 | $3,480 | $3,040 | $440 | 6/3/2024, 11/20/2024 | 408027, 420199 |
| 6 | 12,062,780 | KFU | 33160.59U | 8/13/2024 | $12,760 | $2,880 | $9,880 | 2/29/2024, 11/8/2024 | 407556, 408864 |
| 7 | 12,065,424 | KFU | 33175.60A | 8/20/2024 | $3,480 | $3,040 | $440 | 6/20/2024, 11/20/2024 | 407985, 420195 |
| 8 | 12,071,437 | KFU | 33150.41U | 8/27/2024 | $13,000 | $2,880 | $10,120 | 3/8/2024, 11/8/2024 | 407514, 421003 |
| 9 | D1,046,141 | KSU | 33056.38 | 10/8/2024 | $1,986 | $1,136 | $850 | 10/21/2024 | 408923 |
| 10 | 12,114,620 | KISR | 32366.97U | 10/15/2024 | $1,030 | $480 | $550 | 6/24/2024 | 408965 |
| 11 | 12,116,333 | KFU | 33150.71A | 10/15/2024 | $8,360 | $2,880 | $5,480 | 11/8/2024 | 421024, 421026 |
| 12 | 12,157,086 | SACGC | 33060.73U | 12/3/2024 | $23,490 | $9,005 | $14,485 | 1/11/2024, 2/14/2025 | 405181, 421553 |
| 13 | 12,194,434 | KSU | 33056.80A | 1/14/2025 | $5,730 | $2,880 | $2,850 | 10/21/2024 | 420188, 408719 |
| 14 | 12,227,748 | KSU | 33056.75U | 2/18/2025 | $17,800 | $2,400 | $15,400 | 4/30/2024, 3/12/2025 | 420066, 421334 |
| 15 | 12,303,254 | KSU | 33115.39U | 5/20/2025 | $0 | $0 | $0 | NO PAYMENTS | — |
| 16 | 12,280,479 | SACGC | 33060.78U | 4/22/2025 | $19,960 | $6,160 | $13,800 | 8/22/2024, 2/24/2025 | 408925, 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.
From NGM's own Payments file (205,632 line items, July 2023 – May 2025):
| Client | Total Payments | % of All |
|---|---|---|
| King Faisal University (KFU) | $9,958,817 | 72.4% |
| King Saud University (KSU) | $1,614,599 | 11.7% |
| Kuwait University | $497,431 | 3.6% |
| United Arab Emirates University | $422,874 | 3.1% |
| SACGC | $110,573 | 0.8% |
| KISR | $82,795 | 0.6% |
| Sultan Qaboos University | $60,842 | 0.4% |
| IMSIU | $53,514 | 0.4% |
| Dasman Diabetes Institute | $51,216 | 0.4% |
| All other university/ME clients | $4,858 | 0.0% |
| University/ME Subtotal | $12,857,519 | 93.5% |
| All other clients | $898,198 | 6.5% |
| GRAND TOTAL (Payments file) | $13,755,717 | 100% |
| Source | Description | Amount |
|---|---|---|
| NGM Trust Report (Exhibit A, Deborah Schaefer) | Total receipts across both trust accounts (t23 + t3) | $32,708,669 |
| NGM Payments File | Total 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 |
$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%.
| Method | Revenue Base | 20% Owed | Paid | Difference |
|---|---|---|---|---|
| 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 |
The trust accounts are designated "RL — Richard Litman" as the responsible lawyer, but the money belongs to clients. The June 2025 Trust Listing shows:
| Client | Trust Balance (June 2025) | Responsible Lawyer |
|---|---|---|
| King Faisal University (KFU) | $689,276 | RL |
| King Saud University (KSU) | $264,077 | RL |
| UAEU | $43,862 | RL |
| SACGC | $43,621 | RL |
| KISR | $14,091 | RL |
| Kuwait University | $12,080 | RL |
| All other clients | $144,237 | RL |
| TOTAL TRUST BALANCE | $1,211,244 | RL |
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.
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.
| Issue | Detail |
|---|---|
| Jan 2024 Payment Missing from Workup | The 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 Mismatch | Workup: $16,469.11. Verified Summary: $17,866.40. Neither matches. |
| Jan 2025 Shortfall | Paid $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 Payments | KSU patent issued 5/20/2025, invoiced ~$14,700, with absolutely no payment record in 205,632-line payments file. |
In addition to the two trust accounts documented in Exhibit A (Eagle Bank and Bank of America trust), NGM maintained a third account: a Bank of America wire receipt account ending in 8751 ("Wire_8751"). This account is separate from the trust accounts and was used to receive large international wire transfers from KFU, KSU, and other Middle Eastern university clients.
Wire_8751 functions as a receiving account for incoming international wire transfers. Once received, funds are transferred to other accounts — including, critically, directly to the firm's operating account (Operating_2417) rather than through the trust accounts.
| Feature | Detail |
|---|---|
| Account Type | Bank of America wire receipt account (ending 8751) |
| Primary Use | Receiving international wire transfers from Middle Eastern university clients |
| Key Clients | KFU, KSU, and other university/ME clients |
| Transfer Destination | Funds transferred directly to Operating_2417 |
| Historical Layer | Freedom Bank wires totaling approximately $1.45M |
A single wire transfer illustrates the concern: a $595,214 wire was recorded in the system as $594,214 — exactly $1,000 short. This corrected amount was then transferred directly to the operating account (Operating_2417). Whether this was a clerical error or something else, it demonstrates that wire receipt funds were moving to operating without passing through trust.
The two largest Litman-originated clients — King Faisal University and King Saud University — each maintain a single "umbrella" trust account (docket) through which all payments flow before being distributed to individual patent matters. These umbrella accounts reveal the full scale of revenue under Litman's name.
| Metric | KFU (Docket 36372) | KSU (Docket 35610) | Combined |
|---|---|---|---|
| Total Receipts (via wire) | $10,840,000 | $3,720,000 | $14,560,000 |
| Number of Wire Transfers | 32 | 24 | 56 |
| Total Ledger Entries | 871 | 388 | 1,259 |
| Distributes to | 16+ docket families | Multiple dockets | — |
| Transfer-to-Operating Rate | 79–90% transferred within 1–3 business days | ||
| Current Balance | $84,232 | $92,219 | $176,451 |
Although Goldberg maintains that Litman's matters were handled by staff, the ledger entries reveal his personal authorization on trust account transactions:
| Account | JBG-Authorized Entries | Significance |
|---|---|---|
| KFU Docket 36372 | 4 | Direct involvement in umbrella trust operations |
| KSU Docket 35610 | 7 | More frequent involvement in KSU trust |
On April 10, 2024, a $500,000 transfer was routed through the operating account to move funds between banks. This reverse flow — from operating back through the trust pipeline — raises the question of why client trust funds were in the operating account in the first place. A legitimate inter-bank transfer of trust funds should move directly between trust accounts, not through operating.
Multiple indicators suggest that client trust funds under Litman's name may have been commingled with firm operating funds, in potential violation of Virginia Rule of Professional Conduct 1.15 (Safekeeping Property).
| Indicator | Detail | Significance |
|---|---|---|
| Direct Wire-to-Operating Transfers | Wire_8751 funds transferred directly to Operating_2417 without passing through trust | Client funds entering operating without trust intermediation |
| Deborah Schaefer Statement | Schaefer told Litman the trust accounts were being closed because the firm was "not supposed to have trust money for your own money" | Admission that trust funds and firm funds were being held together |
| $500K Reverse Transfer | $500,000 routed through operating to move between banks (April 10, 2024) | Trust funds in operating account — should have transferred trust-to-trust |
| Rapid Trust-to-Operating Cycle | 79–90% of trust receipts transferred to operating within 1–3 days | Trust accounts functioning as pass-throughs rather than safekeeping |
"A lawyer shall hold property of clients or third persons that is in a lawyer's possession in connection with a representation separate from the lawyer's own property." — Va. RPC 1.15(a)
Virginia RPC 1.15 requires that client funds be held in a separate trust account, clearly identified and distinguished from the lawyer's own property. The rule further requires that records of trust account transactions be maintained and that the lawyer promptly deliver to the client any funds the client is entitled to receive.