1. Executive Summary
Total outstanding pipeline as of the statute-of-limitations cutoff date (June 15, 2025), combining billed-but-unpaid accounts receivable and unbilled work in progress.
Total Pipeline Outstanding
$10,497,848
Litman 20% Entitlement: $2,099,570
AR Outstanding
$8,918,591
Billed, unpaid invoices
Work in Progress
$1,579,257
Unbilled fees + disbursements
Total Billed (All Years)
$32,448,690
2017 through June 2025
Collection Rate
72.5%
$23.5M collected of $32.4M
Why this matters: Under the Combination Agreement, Litman is entitled to 20% of all fees collected on his matters "regardless of when received." The $8.9M in outstanding AR represents future collections on which Litman's share has not yet been paid. When these invoices are collected, Litman is owed his percentage. Goldberg has no contractual right to write off these receivables to avoid paying Litman.
2. Accounts Receivable by Year (2017–2025)
Year-by-year billing, collections, and outstanding balances across all Litman-originated matters.
| Year | Billed | Paid | Outstanding | Coll. Rate |
|---|---|---|---|---|
| 2017 | $1,507,332 | $1,064,258 | $443,074 | 70.6% |
| 2018 | $4,256,103 | $2,636,292 | $1,619,811 | 61.9% |
| 2019 | $3,047,637 | $2,287,458 | $760,179 | 75.1% |
| 2020 | $2,667,104 | $1,200,534 | $1,466,570 | 45.0% |
| 2021 | $1,482,017 | $961,313 | $520,704 | 64.9% |
| 2022 | $1,408,556 | $1,133,291 | $275,265 | 80.5% |
| 2023 | $8,052,091 | $7,630,014 | $422,077 | 94.8% |
| 2024 | $8,563,278 | $6,142,456 | $2,420,822 | 71.7% |
| 2025 | $1,464,572 | $474,484 | $990,089 | 32.4% |
| TOTAL | $32,448,690 | $23,530,099 | $8,918,591 | 72.5% |
2020 collection rate of 45.0% is the worst year — coinciding with Goldberg taking over operations after the 6/15/2020 agreement "termination" and the onset of COVID. Over $1.4M from 2020 alone remains uncollected.
3. AR Aging Analysis
Outstanding receivables grouped by vintage period. Note the concentration in 2024 billings.
| Period | Outstanding | % of Total |
|---|---|---|
| Pre-2020 (2017–2019) | $2,823,064 | 31.7% |
| 2020–2022 | $2,262,539 | 25.4% |
| 2023 | $422,077 | 4.7% |
| 2024 | $2,420,822 | 27.2% |
| 2025 (through June 15) | $990,089 | 11.1% |
| TOTAL | $8,918,591 | 100.0% |
Contract says "regardless of when received" — There is no write-off provision in the Combination Agreement. Aged receivables remain collectible, and Litman's 20% share attaches to every dollar collected regardless of invoice vintage. The $2.8M in pre-2020 AR is particularly significant: these are Litman's own clients from when he was actively practicing.
4. Client Breakdown — 2025 Invoice Summary
Outstanding invoices by client for the 2025 billing year (through June 15, 2025). King Saud University dominates the receivables.
| Client | Outstanding |
|---|---|
| King Saud University | $733,302 |
| King Faisal University | $91,516 |
| Sabah Al-Ahmad Center | $75,719 |
| UAEU | $45,255 |
| Kuwait University | $25,546 |
| KISR | $6,548 |
| IMSIU | $4,300 |
| Others | ~$8,000 |
King Saud University alone accounts for $733K in 2025 outstanding. These are all Litman-originated clients — Middle Eastern universities that came to NGM because of Richard Litman's reputation and personal relationships. Goldberg continues billing under Litman's name and client base.
5. Work in Progress ($1.58M)
Unbilled time and disbursements as of June 15, 2025 — work performed but not yet invoiced to clients.
Unbilled Fees
$1,292,567
3,640 hours recorded
Unbilled Disbursements
$319,695
Filing fees, translation, etc.
Less Retainers
($33,005)
Client deposits on hand
Net WIP
$1,579,257
Total unbilled pipeline
WIP Aging
| Aging Bucket | Amount | % of WIP |
|---|---|---|
| Current (0–30 days) | $512,000 | 32.4% |
| 30–60 days | $383,000 | 24.3% |
| 60–90 days | $164,000 | 10.4% |
| 90–120 days | $148,000 | 9.4% |
| >120 days | $373,000 | 23.6% |
| TOTAL | $1,580,000 | 100.0% |
$373K in WIP is over 120 days old. This unbilled work may never be invoiced — representing potential value destruction that directly reduces Litman's future entitlement.
6. KFU Docket Pipeline
King Faisal University — the largest single client — has a massive pipeline of active patent dockets generating ongoing fees.
Total KFU Dockets
2,833
Active matter numbers
Unique Inventions
1,917
Distinct patent families
Opened Post-Arbitration
2,554
91% of all KFU dockets
Not Yet Billed
26
Opened but $0 invoiced
KFU Dockets Opened by Year
| Year | Dockets Opened | % of Total |
|---|---|---|
| 2021 | 39 | 1.4% |
| 2022 | 214 | 7.6% |
| 2023 | 1,322 | 46.7% |
| 2024 | 1,103 | 38.9% |
| 2025 (through June) | 129 | 4.6% |
| Post-Arbitration Total | 2,554* | ~91% |
* Remaining ~279 dockets predate the June 14, 2023 arbitration.
91% of KFU dockets were opened AFTER the arbitration. Goldberg built this entire practice on the back of Litman's client relationship with KFU. Each docket generates filing fees, prosecution fees, and maintenance fees over a 20+ year patent lifecycle. This pipeline alone is worth millions in future fees — all subject to Litman's 20% share.
7. What This Means
Future entitlement is not speculative. The $8.9M in outstanding AR represents invoices already sent to clients. When collected, Litman's 20% share ($1.78M on AR alone) becomes immediately payable. The Combination Agreement contains no expiration on this obligation.
The pipeline keeps growing. With 2,833 active KFU dockets and ongoing prosecution across all clients, new billing will continue for years. Each patent has a 20-year lifecycle of maintenance fees, continuations, and foreign filings — all generating fees subject to the 20% allocation.
No write-off provision protects Goldberg. The contract says Litman receives 20% of fees "regardless of when received." Goldberg cannot unilaterally write off aged receivables or decline to collect from clients to reduce Litman's share. Any such action would constitute a breach.
Settlement must account for pipeline value. A lump-sum settlement that ignores the $10.5M pipeline dramatically undervalues Litman's position. At 20%, the pipeline alone represents $2.1M in entitlement — before any damages, interest, or penalties for misappropriation.
Goldberg's financial incentive to settle is clear. Every month of delay means more collections on which he owes 20%. The 2024 collection rate of 71.7% suggests the outstanding $2.4M from that year will largely be paid, generating additional entitlement. Time works in Litman's favor.
Litman v. Goldberg, Index No. 524343/2025 — NY Sup. Ct., Kings County
Prepared April 4, 2026 — Data as of June 15, 2025
PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT