CATALOG OF UNAUTHORIZED USES OF RICHARD C. LITMAN'S NAME
Litman v. Goldberg, Index No. 524343/2025 — NY Civil Rights Law SS 50-51
Prepared: April 15, 2026
Purpose: Each type below constitutes a separate category of SS 51 "publication" of Litman's name for commercial purposes. Under the "deck of cards" theory, each individual instance is a separate actionable use.
TYPE 1: Email Attachment Bearing Litman's Name
Description: Any email sent by NGM staff to a client (or filed with the USPTO) with an attached document that contains "Richard C. Litman" or "Richard Litman" on its face. Document types include: invoices, powers of attorney (POAs), filing receipts, office actions, Notices of Allowance (NOAs), patent front pages, assignment cover sheets, fee schedules, engagement letters, and maintenance fee statements.
Each such email is a separate SS 51 "publication" dated when SENT (not when the underlying patent issues publicly). The attachment is the instrument; the email is the dissemination.
Exemplar 1: Invoice to University of Sharjah
- Bates: C2051472_ND0000000011.msg
- Date: September 17, 2019
- Sender: Martha Long (mlong@nathlaw.com)
- Recipient: Dr. Mohamed Al Hemairy (malhemairy@sharjah.ac.ae)
- CC: "Richard Litman" rlitman@nathlaw.com; uos@4patent.com
- Attachment:
32989_16_Disclosure Review Invoice.pdf
- Name on document: Invoice bears the firm name and is sent under Litman's CC authority; Litman's name appears in the CC line and the invoice header references CN-37833 / Richard C. Litman as correspondent
Exemplar 2: Maintenance Fee Statement to KISR
- Bates: C2051472_ND0000001810.msg
- Date: September 25, 2020 (post-SOL)
- Sender: David Johnson (djohnson@nathlaw.com)
- Recipient: Ahmad Ibrahim Haji (ahaji@kisr.edu.kw)
- CC: Howard Kline, Martha Long, kisr@4patent.com (plus multiple KISR staff)
- Attachment:
32366.32 maintenance-fee-statement.pdf
- Name on document: The maintenance fee statement references Patent 9,609,874, Docket 32366.32 — all filings under this docket bear "Richard C. Litman" as attorney of record via CN-37833
Exemplar 3: Hashtag Sports Trademark Letter (Latest Confirmed)
- Source: evidence/IMG_1674_HashtagSports_Letter_20250724.jpg (iCloud photo)
- Date: July 24, 2025 — 6 days AFTER email elimination, 44 days AFTER website removal demand
- Signed by: "Richard C. Litman" and "Howard W. Kline"
- Recipient: Anthony Caponiti at Activ8Social LLC d/b/a Hashtag Sports
- Re: U.S. Trademark Reg. No. 4,697,459 ("HASHTAG SPORTS"), Ref: 32662.00
- Significance: Latest confirmed direct name use. A letter with Litman's name signed and mailed AFTER email elimination and AFTER the litigation trigger.
Corpus Count
- Emails with attachments where "Richard Litman" appears in CC/To: ~12,488 across ND0001+ND0002 (3,350 in ND0001 + 9,138 in ND0002 with display name "Richard Litman")
- Emails with attachments (attachment_count > 0) referencing Litman: Thousands. The 11,243 extracted email attachments represent a subset; each is a potential separate use.
- 206 outgoing USPTO documents identified across 21 patents bearing Litman's name (each a filing receipt, office action response, NOA, etc.)
TYPE 2: Email CC Line Displaying "Richard Litman" to Clients
Description: When NGM staff send emails to clients and CC "Richard Litman" rlitman@nathlaw.com or "Richard Litman" litman@4patent.com, the client's email client displays "Richard Litman" as a named participant in the communication. This is a publication of his name to the client — it tells the client that Richard Litman is involved in their matter, lending his professional reputation to the communication. The client sees the name; the client relies on the name.
Exemplar 1: Qatar Foundation NOA Email
- Bates: C2051472_ND0000000202.msg
- Date: September 24, 2019
- Sender: Martha Long (mlong@nathlaw.com)
- Recipient: Aisulu Anarbekova (aanarbekova@qf.org.qa) — Qatar Foundation staff
- CC: IP Management (ipmanagement@qf.org.qa); qf@4patent.com; John T. McEntire; "Richard Litman" rlitman@nathlaw.com; Joshua Goldberg; Jerry Meyer
- Subject: "ACTION REQUIRED -- Notice of Allowance for Qatar Foundation -- Docket 33005.67"
- Client sees: "Richard Litman" in the CC line — publication of his name in connection with the client's patent matter
Exemplar 2: Howard Kline Trademark Email CC'ing Litman to External Client
- Bates: C2051472_ND0000002411.msg
- Date: October 8, 2020 (post-SOL)
- Sender: Howard Kline (hkline@nathlaw.com)
- Recipient: jschweer@att.net (James Schweer — new trademark client)
- CC: "Richard Litman" rlitman@nathlaw.com; David Johnson; Docketing NVA; Martha Long; cs@4patent.com
- Subject: "RE: trademark; Our Ref: 19420.08"
- Attachment:
Engagement Agreement.pdf
- Client sees: "Richard Litman" on a BRAND NEW client engagement — Litman's name lends credibility to the onboarding of a client he never met
Exemplar 3: KFU Client Correspondence (Post-SOL, Post-Arbitration)
- Bates: C2051472_ND0000184148.msg (ND0002)
- Date: December 5, 2023 (post-arbitration)
- Sender: Howard Kline (hkline@nathlaw.com)
- Recipient: Victor S (victor@loodindustries.com) — One Choice Nutrition LLC
- CC: "Richard Litman" rlitman@nathlaw.com; Joshua Goldberg
- Subject: "RE: ONE CHOICE NEW APPLICATIONS" (Trademark SN 97/678,503 and 98/006,931)
- Client sees: "Richard Litman" on ongoing TTAB trademark proceedings — 18 months after the arbitration award
Corpus Count
- ND0001: 8,953 emails where Litman email addresses appear in the CC field
- ND0002: Additional thousands (ND0002 has 9,138 emails with "Richard Litman" display name)
- Combined estimated total: 12,000+ emails where clients see "Richard Litman" as a participant
- Date range: September 2019 through at least December 2025 (per Finding #106: 8,024 emails continued arriving at "eliminated" accounts post-July 18, 2025)
TYPE 3: Howard Kline Signature Block Referencing Firm Name
Description: Howard Kline's emails to external clients include a signature block displaying "NATH, GOLDBERG & MEYER" with the firm's Alexandria address. The firm itself bears a name that, through its operations, is inextricably associated with Litman. More directly, Nath & Associates PLLC (Goldberg's entity) owns the federal trademark "LITMAN LAW OFFICES, LTD." (SN 74440111, Reg #1861297) — Kline is the attorney of record on that trademark. Every Kline email to a client thus deploys Litman's professional identity through the firm infrastructure that was built on Litman's name and reputation.
Additionally, many Kline emails CC "Richard Litman" directly, compounding the name use.
Exemplar 1: New Trademark Client Solicitation (Saudi Arabia)
- Bates: C2051472_ND0000002254.msg
- Date: October 6, 2020 (post-SOL)
- Sender: Howard Kline (hkline@nathlaw.com)
- Recipient: Tijani Mustafa (mtijani@wahaj.com.sa) — Saudi Advanced Technologies Company (Wahaj)
- CC: cs@4patent.com; David Johnson
- Signature block: "Howard W. Kline / Managing Attorney of Trademark Department / NATH, GOLDBERG & MEYER / 112 S. West Street, Alexandria, VA 22314 / Tel: 703-548-6284"
- Note: This client came through clientservice@4patent.com — a @4patent.com alias on Litman's personal domain, routed through NGM's M365 tenant (Finding #43). Martha Long introduced Kline as "our attorney" to a client reached via Litman's domain infrastructure.
Exemplar 2: One Choice Nutrition (TTAB Proceedings)
- Bates: C2051472_ND0000184148.msg
- Date: December 5, 2023 (post-arbitration)
- Sender: Howard Kline (hkline@nathlaw.com)
- Recipient: Victor S (victor@loodindustries.com)
- CC: "Richard Litman" rlitman@nathlaw.com; Joshua Goldberg
- Signature block: "Howard W. Kline / Partner / NATH, GOLDBERG & MEYER / 112 S. West Street, Alexandria, VA 22314 / Tel: 703-548-6284 || 703-486-1000 / Direct: 703-940-5610"
- Note: Kline's title changed from "Managing Attorney of Trademark Department" to "Partner" — but the signature block still uses the firm name built on Litman's practice
Corpus Count
- Emails FROM Howard Kline: 2,678 total (74 in ND0001 + 2,604 in ND0002)
- Emails where Kline is CC'd (broader exposure): 8,075 total (869 in ND0001 + 7,206 in ND0002)
- 91% of Kline's emails CC'd Litman (per Finding #8)
- Date range: September 2020 through at least January 2026
TYPE 4: Nicola Pizza Power of Attorney and Trademark Filings
Description: Nicola Pizza, Inc. (Client #135706, CN-24396) is a Litman-originated client with 9 active trademark registrations and 1 new application, all handled through the CN-24396 customer number that was transferred alongside CN-37833 in Amendment Paragraph 3(e). The USPTO TSDR records list "Richard Litman" among the appointed attorneys on Nicola Pizza trademark matters. Each POA, filing, and office action response under these dockets is a separate SS 51 use.
Exemplar 1: TSDR Record — "THE ORIGINAL NIC-O-BOLI"
- Source: evidence/IMG_1681_NicolaPizza_TSDR_Record.jpg (iCloud photo)
- Docket: 6217.09
- USPTO Record: Lists Richard Litman among appointed attorneys alongside Collins, Safian B. Goldberg, Jerald L. Meyer, Nancy E. Perkins
- Correspondence: Handled by Howard W. Kline
- Significance: Litman's name appears on the official USPTO trademark attorney listing — a government-published record visible to the public and the client
Exemplar 2: "TASTE OF THE 1ST STATE" — New Project July 7, 2025
- Source: Finding #115 / output/EMAIL_RESCAN_REPORT_2026-04-14.md
- Date: July 7, 2025 — post-SOL, post-litigation trigger
- Description: New Nicola Pizza trademark project ("TASTE OF THE 1ST STATE") arriving at the firm while Litman's name remains on all existing Nicola Pizza filings
- Significance: Active new business under Litman's name continuing in the late-period window
- Source: Finding #72 / output/CN_24396_SEARCH_RESULTS.md
- Description: Poppiti (Lewis Brisbois partner) contacted rlitman@nathlaw.com for Nicola Pizza trademark work — the client contact came through Litman's email address
- Financial data: All 9 Nicola Pizza dockets billed under "RL" (Richard Litman) in NGM billing system; $9,520 in trust receipts (Dec 2024-Jan 2025) coded to "RL"
Corpus Count
- Nicola Pizza emails in corpus: 1,244 (709 in ND0001 + 535 in ND0002)
- Active trademark registrations: 9 + 1 new application
- Each registration renewal, Section 8/9/15 declaration, and new filing is a separate use
TYPE 5: Post-Elimination Client Emails CC'ing Litman (KSU Invoice Example)
Description: After Goldberg claimed to have "eliminated" Litman's email accounts on July 18, 2025, NGM continued to copy Litman's email addresses on client correspondence — including financial correspondence about invoice payments. Finding #106 establishes that 8,024+ emails arrived at "eliminated" accounts between July 21 and December 31, 2025. Each such email that was part of client correspondence (not spam/newsletters) is a separate use: it tells the email system, the client, and the record that "Richard Litman" is a participant.
Exemplar 1: KSU Emails in July 2025
- Source: EMAIL_METADATA_ND0001.csv and ND0002.csv
- Date range: July 2025
- Total KSU emails in corpus: 19,024 (6,260 in ND0001 + 12,764 in ND0002)
- ksu@4patent.com alias: 19,701 emails total (per Finding #46) — every one routed through Litman's personal domain
- Note: Uncle's specific recollection is of being copied on July 28, 2025 emails about KSU invoice payments. The exact Bates number for the specific July 28 KSU invoice email requires further search of the KSU sub-corpus. The general pattern is proven: KSU correspondence routinely CC'd rlitman@nathlaw.com and routed through ksu@4patent.com through the entire period.
Exemplar 2: BHC Management USPTO Notice — August 20, 2025
- Bates: Per Finding #54
- Date: August 20, 2025 — one month after alleged elimination
- Description: Independent USPTO-generated correspondence on trademark Serial 99034636 sent to rlitman@nathlaw.com
- Significance: Third-party (USPTO) proof that Litman's name remained the correspondence address of record. Not just NGM's choice — the U.S. government was still publishing under his name.
Exemplar 3: USPTO Trademark Notification — August 26, 2025
- Source: Finding #40
- Date: August 26, 2025 — 39 days after alleged elimination
- Description: USPTO trademark notification still CC'd to rlitman@nathlaw.com
- Significance: Ongoing government correspondence using Litman's name and email address
Corpus Count
- Total emails to "eliminated" accounts post-July 18, 2025:
- litman@4patent.com: 7,519 (through December 31, 2025)
- r.litman@4patent.com: 334
- rlitman@nathlaw.com: 171
- TOTAL: 8,024+
- Each client-correspondence email in this count is a separate post-elimination use
TYPE 6: Assignment Documents — Goldberg Signs Under Litman's Mailing Address
Description: USPTO assignment documents (Nunc Pro Tunc Assignments, regular assignments, and assignment cover sheets) where Joshua B. Goldberg personally signed the document but the correspondence/mailing address block displays "Richard C. Litman" or routes through CN-37833 (which was registered to "Richard C. Litman" until May 1, 2025). Each recorded assignment is a permanent government record displaying Litman's name.
Exemplar 1: Nunc Pro Tunc Assignment — Reel 007281, Frame 0821
- Source: USPTO Assignment Database; iCloud photo (Finding #105 — uncle has physical photograph)
- Date: Executed May 3, 2021; Recorded June 2, 2021
- Signed by: "RICHARD C. LITMAN, ASSIGNOR" to "NATH & ASSOCIATES PLLC, ASSIGNEE"
- Key language: States that Litman "owns his name, signature, voice, image, photograph or likeness" — the very rights NGM later exploited
- Significance: Goldberg's own recorded document explicitly carves out Litman's personal name rights. Yet Goldberg continued using those rights. This is both a use (the document displays Litman's name on a government record) and the document that DESTROYS the consent defense.
Exemplar 2: December 21, 2023 "Bombshell" — POA + KFU Assignment Same Day
- Source: Finding #3 / Application 18/392,663
- Date: December 21, 2023 (post-arbitration)
- Signed by: Joshua B. Goldberg (Reg. 44126)
- Documents: Goldberg signed BOTH the Power of Attorney (listing "Richard C. Litman" as one of the practitioners) AND the KFU assignment cover sheet on the same day
- Assignment correspondent pattern: "Richard C. Litman" → "RICHARD C. LITMAN" (Oct-Dec 2023) → "JOSHUA GOLDBERG" (2024-2025) — per Finding #44, the assignment correspondent shifted but Litman's name remained on the practitioner roster
Exemplar 3: KSU Brooklyn-Signed Disbursement — April 4, 2023
- Source: Finding #59
- Date: April 4, 2023
- Signed by: Joshua B. Goldberg from Brooklyn, NY
- CC: ksu@4patent.com (Litman's domain)
- Significance: Single document combining personal jurisdiction (Brooklyn), personal participation (KSU disbursement), and use of Litman's domain alias — three pillars in one exhibit
Corpus Count
- Assignment PDFs in evidence: 17 assignment PDFs + 13 assignment screenshots
- POAs signed by Goldberg personally: 16 of 21 (Reg. 44126) — all post-SOL, most post-arbitration
- Latest POA filing: June 25, 2025 (Finding #79) — 10 days after contract termination
- Each POA and assignment is a separate recorded government document bearing Litman's name
TYPE 7: Email Forwarding Patent PDF = Republication of Patent
Description: Each email that forwards or attaches a patent PDF (eGrant notification, NOA + patent copy, patent front page) bearing "Richard C. Litman" on Line 74 (Attorney, Agent, or Firm) is a SEPARATE republication of that patent — distinct from the USPTO's initial publication. The date of the SS 51 use is when the email was SENT, not when the patent was published by the USPTO.
This applies to: (a) eGrant notification emails from the USPTO to the firm, which are then forwarded to clients with the patent PDF attached; (b) emails from NGM staff to clients attaching patent front pages for their records; (c) internal distribution of patent PDFs through client aliases (kfu@4patent.com, ksu@4patent.com, etc.).
Exemplar 1: eGrant Notifications
- Source: EMAIL_METADATA_ND0001.csv and ND0002.csv
- Total eGrant emails in corpus: 1,878 (241 in ND0001 + 1,637 in ND0002)
- Date range: 2019 through January 2025 (when Line 74 switched to Goldberg)
- Each eGrant notification references a specific patent number and includes or links to the patent document bearing "Richard C. Litman" on Line 74
- Pattern: USPTO sends eGrant to the firm (via litman@4patent.com or rlitman@nathlaw.com) -> NGM staff forward to client with attached patent PDF -> client receives document bearing Litman's name -> separate SS 51 publication
Exemplar 2: Notice of Allowance Forwarded to Client with Litman CC'd
- Bates: C2051472_ND0000000202.msg
- Date: September 20-24, 2019 (thread)
- Sender: Martha Long (mlong@nathlaw.com)
- Recipient: Qatar Foundation (Nancy Goel, then Aisulu Anarbekova)
- CC: "Richard Litman" rlitman@nathlaw.com; Joshua Goldberg; Jerry Meyer; qf@4patent.com
- Subject: "ACTION REQUIRED -- Notice of Allowance for Qatar Foundation -- Docket 33005.67"
- Description: NOA forwarded to client. The underlying patent filing bears "Richard C. Litman" as attorney via CN-37833. The email itself puts Litman's name in the CC line. The attached NOA references the patent application where Litman is the named attorney.
Exemplar 3: Patent Front Pages (905 Patents)
- Source: 905-patent backbone dataset (richard_litman_attorney_issued_patents_since_2020-06-15.csv)
- Total patents with Litman on Line 74: 905 (issued June 15, 2020 through January 14, 2025)
- Each time any of these 905 patent PDFs was emailed to a client, it constituted a separate republication
- Conservative estimate: At minimum 905 eGrant notifications + thousands of follow-up emails forwarding patent copies = thousands of individual republications
- KFU alone: 574 U.S. patents through December 2024 (Finding #60) — KFU's share of the 905 represents hundreds of individual patent republications
Corpus Count
- eGrant-related emails: 1,878
- NOA-related emails referencing patents with attachments: ~3,147
- Patents on Line 74: 905
- Conservative total of email-based republications: 5,000+ individual SS 51 uses (each email attaching or referencing a patent PDF bearing Litman's name)
SUMMARY TABLE
| Type |
Description |
Exemplar Count |
Estimated Total Uses |
Date Range |
| 1 |
Attachment bears Litman's name |
3 cited |
11,243+ attachments extracted |
Sept 2019 - July 2025 |
| 2 |
CC line shows "Richard Litman" to client |
3 cited |
12,000+ emails |
Sept 2019 - Dec 2025 |
| 3 |
Kline signature block / firm name |
2 cited |
2,678 Kline emails |
Sept 2020 - Jan 2026 |
| 4 |
Nicola Pizza POA/TM filings |
3 cited |
1,244 emails + 10 TM dockets |
Ongoing through July 2025 |
| 5 |
Post-elimination emails CC'ing Litman |
3 cited |
8,024+ post-July 18, 2025 |
July 21 - Dec 31, 2025 |
| 6 |
Assignment signed by Goldberg / Litman address |
3 cited |
16 POAs + 17 assignments + 13 screenshots |
Post-SOL through June 2025 |
| 7 |
Email with patent PDF = republication |
3 cited |
5,000+ estimated |
June 2020 - Jan 2025 |
GRAND TOTAL (conservative): 30,000+ individual SS 51 uses across all seven types.
CROSS-REFERENCE TO FIVE-TIER FRAMEWORK
These 7 types map to the previously established 5-tier SS 51 framework (Finding, project memory):
- Tier 1 (USPTO Government Records): Types 1, 6, 7
- Tier 2 (Client-Facing Communications): Types 2, 3, 4, 5
- Tier 3 (Domain Infrastructure): Types 2, 3, 5 (via @4patent.com and @litmanlaw.com aliases)
- Tier 4 (Website/Public-Facing): Covered separately (nathlaw.com bio, litmanlaw.com)
- Tier 5 (Trademark/TTAB): Types 3, 4
Each type is independently actionable. The types are cumulative, not alternative. A single email can constitute multiple types simultaneously (e.g., an email CC'ing Litman [Type 2] with an attachment bearing his name [Type 1] sent by Kline with his firm signature block [Type 3] forwarding a patent PDF [Type 7]).
KEY LEGAL POINTS
-
Each instance is dated when the email was SENT — not when the underlying patent or trademark was published by the USPTO. This is uncle's email attachment theory (Finding #14).
-
Post-July 18, 2025 uses are the strongest — Goldberg cannot claim inadvertence after claiming elimination. The 8,024 post-elimination emails prove the accounts were not eliminated but ACCESS-RESTRICTED — Goldberg kept the mailbox running to intercept mail (Finding #106).
-
The "deck of cards" theory applies to ALL types — each individual email, each individual attachment, each individual POA signature is a separate card in the deck.
-
Goldberg ADMITTED the name use — His Answer (Doc #65, Jan 20, 2026) ADMITS Litman's name appeared on patent front pages and the NGM website after June 15, 2020 (paragraphs 32, 72).
-
Exhibit R destroys consent defense — Goldberg's own recorded asset-sale/trademark-assignment agreement explicitly carved out Litman's personal "name, signature, voice, image, photograph or likeness" (Finding #86).