SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ───────────────────────────────────────── RICHARD C. LITMAN, Plaintiff, -against- Index No. 524343/2025 JOSHUA B. GOLDBERG, Defendant. ───────────────────────────────────────── # PLAINTIFF'S VERIFIED BILL OF PARTICULARS Plaintiff Richard C. Litman ("Plaintiff"), by and through his attorneys, Wachtel Missry LLP, as and for his Verified Bill of Particulars to Defendant Joshua B. Goldberg ("Defendant"), submits the following: --- ## GENERAL OBJECTIONS Plaintiff objects to each Demand to the extent that it: (a) seeks information beyond the scope of a Bill of Particulars under CPLR 3041 and 3043; (b) seeks evidentiary detail or mathematical damage calculations prior to the completion of fact and expert discovery; (c) requests the disclosure of information protected by the attorney work-product doctrine or any applicable privilege; (d) seeks information equally or exclusively within Defendant's possession, custody, or control, or otherwise publicly available; or (e) seeks discovery regarding causes of action dismissed by the Court's December 5, 2025 Order. Responses are limited to the surviving claim under NY Civil Rights Law §§ 50-51 (Count V). Plaintiff reserves the right to supplement or amend any response as discovery proceeds. These General Objections are incorporated into each response below. --- ## SPECIFIC RESPONSES ### DEMAND NO. 1: Identify and set forth the patent number for each patent you claim evidences a violation of New York Civil Rights Law §§ 50-51 by Defendant. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff states that Defendant caused Plaintiff's name, "Richard C. Litman," to appear as the attorney of record on approximately **905 United States patents** issued after June 15, 2020, the date Plaintiff became disabled and ceased active practice. Of these 905 patents, the following **thirteen (13) patents** were issued within the one-year statute of limitations period preceding the filing of this action on July 21, 2025, and are set forth here as representative examples: | No. | Patent Number | Date Issued | Title | |-----|--------------|-------------|-------| | 1 | US 12,043,608 B1 | July 23, 2024 | 2-(Benzo[b]thiophen-3-yl)-1-butyl-4,5-diphenyl-1H-imidazole as an anti-inflammatory and anti-microbial compound | | 2 | US 12,043,609 B1 | July 23, 2024 | 6'(4-methoxyphenyl)-2'-alkoxy-3,4'-bipyridine-3'-carbonitrile as antimicrobial compounds | | 3 | US 12,049,459 B1 | July 30, 2024 | 3-(4,5-Diphenyl-2-(pyridin-3-yl)-1H-imidazol-1-yl)-N,N-dimethylpropan-1-amine as an anticancer compound | | 4 | US 12,054,460 B1 | August 6, 2024 | 9-(5-bromo-2-hydroxyphenyl)-10-[3-(dimethylamino)propyl]-3,4,6,7,9,10-hexahydroacridine-1,8(2H,5H)-dione as an antimicrobial compound | | 5 | US 12,054,464 B1 | August 6, 2024 | Methyl 4-((5-(3-fluorophenyl)-4-phenyl-4H-1,2,4-triazol-3-ylthio)methyl)benzoate as an antimicrobial compound | | 6 | US 12,062,780 B1 | August 13, 2024 | Hydrovoltaic power generation devices utilizing carbon sphere-coated nickel foam/PET substrate | | 7 | US 12,065,424 B1 | August 20, 2024 | 6'(4-methoxyphenyl)-2'-alkoxy-3,4'-bipyridine-3'-carbonitrile as antimicrobial compounds | | 8 | US 12,071,437 B1 | August 27, 2024 | Pyrazolo[1,5-a]pyrido[4,3-e]pyrimidine-2-carboxylic acids as CK2 inhibitors | | 9 | US D1,046,141 S | October 8, 2024 | Dental tool for anchoring a rubber dam | | 10 | US 12,114,620 B1 | October 15, 2024 | Vertical tubers planter and harvester | | 11 | US 12,116,333 B1 | October 15, 2024 | 3,3'-(hydrazine-1,2-diyl)bis(1-(naphthalen-2-yloxy)propan-2-ol) as an ecofriendly insecticidal agent | | 12 | US 12,157,086 B1 | December 3, 2024 | Amine liquid seal in a flare system | | 13 | US 12,194,434 B1 | January 14, 2025 | Imidazolium ionic liquids made using cardanol extracted from cashew nutshell oil to enhance crude oil recovery in oilfields | These 13 patents are representative of the approximately 905 patents on which Plaintiff's name was used without authorization. All 905 patents are publicly accessible through the USPTO Patent Full-Text and Image Database. Plaintiff reserves the right to supplement this list and to provide the complete list through discovery. The 905 patents span assignments to institutional clients originated by Plaintiff over the course of his career, including but not limited to: King Faisal University (approximately 467 patents in 2024 alone); King Saud University; Kuwait University; United Arab Emirates University; Dasman Diabetes Institute; Sabah Al Ahmad Center for Giftedness and Creativity; Kuwait Institute for Scientific Research; and additional Middle Eastern institutions and individual U.S. inventors. --- ### DEMAND NO. 1(a): Describe in detail how the patents identified herein violate New York Civil Rights Law §§ 50-51. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff responds as follows: Each identified patent constitutes a public, permanent government record that uses Plaintiff's name — specifically, "Richard C. Litman" on Line 74 (Attorney, Agent, or Firm) — in connection with the provision of professional legal services for the purposes of trade, without Plaintiff's written consent, in violation of NY Civil Rights Law §§ 50-51. Defendant caused Plaintiff's name to appear on these patents through a specific, deliberate mechanism: Defendant personally signed PTO/AIA/82A Power of Attorney transmittals using his personal USPTO registration number (Reg. No. 44,126), designating Customer Number CN-37833 (Nath, Goldberg & Meyer) as the correspondence address while keeping Plaintiff's name as the attorney of record. Once filed, the USPTO system automatically associated Plaintiff's name with every subsequent prosecution document and the issued patent itself. Defendant personally signed sixteen (16) such Powers of Attorney, all after June 15, 2020, and fourteen (14) of the sixteen after the June 14, 2023 arbitration decision. Defendant's most recent Power of Attorney was signed on January 17, 2025, three days after Plaintiff's name was replaced on new patent grants. Additionally, Defendant caused Plaintiff's name to appear on more than 200 outgoing USPTO prosecution documents, including Filing Receipts, Office Actions, Notices of Allowance, and Issue Notifications, each of which is a separate government record constituting a separate publication of Plaintiff's name within the meaning of Section 51. Defendant knew Plaintiff was disabled and not performing legal work. Defendant admitted in his Answer (Paragraph 39) that Plaintiff became physically disabled in June 2020. Despite this knowledge, Defendant continued signing Powers of Attorney listing Plaintiff as attorney of record for an additional four and one-half years. On December 21, 2023 — 190 days after the arbitration decision — Defendant signed both a Power of Attorney transmittal and a patent assignment cover sheet for a single King Faisal University application, both listing Plaintiff's name as the correspondent attorney. --- ### DEMAND NO. 1(b): State with specificity every item of damage that was caused to you by the publication of the patents identified herein including the total amount you claim for each damage item. **RESPONSE:** Subject to the foregoing General Objections, and subject further to the objection that this Demand seeks premature quantification of damages prior to completion of expert discovery and accounting, Plaintiff responds as follows: Plaintiff claims the following categories of damages: **(a) Compensatory damages** for the unauthorized commercial exploitation of Plaintiff's name, professional identity, and reputation, including the fair market value of the use of Plaintiff's name, the revenues generated by Defendant through such use, and Plaintiff's loss of control over his professional identity. The firm collected approximately $18.5 million in legal fees from Plaintiff's originated clients during the period June 15, 2020 through May 2025, all while Plaintiff's name appeared as the attorney of record. **(b) Unjust enrichment** in an amount representing the commercial benefit Defendant derived from using Plaintiff's name to secure and maintain client relationships, generate revenue, and represent clients before the USPTO for a fee. Between January 14, 2025 and January 21, 2025, Defendant replaced Plaintiff's name with his own on new patent grants, demonstrating both Defendant's control over the name attribution and the commercial value Defendant derived from Plaintiff's name during the years he used it. **(c) Punitive/exemplary damages** as authorized by NY Civil Rights Law § 51, based upon Defendant's knowing, willful, and continuous unauthorized use of Plaintiff's name over a period of more than four years, continuing after the June 14, 2023 arbitration decision, and after Plaintiff expressly objected to the use of his name. **(d) Professional liability exposure.** Each of the 905 patents bearing Plaintiff's name exposes Plaintiff to potential malpractice claims for legal work he did not perform, review, or supervise. **(e) Injunctive relief** requiring Defendant to cease use of Plaintiff's name, file attorney-of-record changes with the USPTO, and notify clients of the unauthorized use. The total dollar amount of each item of damages will be established at trial with the benefit of fact and expert discovery. Plaintiff reserves the right to supplement this response. --- ### DEMAND NO. 1(c): Describe in detail how the alleged use of your name on the identified patents caused each item of damage set forth above in subsection (b). **RESPONSE:** Subject to the foregoing General Objections, Plaintiff responds as follows: Defendant's use of Plaintiff's name on the identified patents publicly and permanently associated Plaintiff with ongoing commercial legal services that Plaintiff did not perform, enabling Defendant to extract commercial benefit and revenue derived from Plaintiff's name recognition and established institutional relationships. The publication of Plaintiff's name on each patent falsely communicated professional responsibility to international clients, the USPTO, and the public. Former clients continue to contact the firm specifically seeking "Richard Litman," demonstrating the commercial drawing power of Plaintiff's name. Plaintiff was deprived of the ability to control or negotiate the use of his professional identity. --- ### DEMAND NO. 2: Aside from the patents listed above, identify and set forth in detail all other use(s) of your name or likeness that you claim evidences a violation of New York Civil Rights Law §§ 50-51 by Defendant. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff responds as follows: In addition to the 905 issued patents, Defendant used Plaintiff's name without authorization in the following categories: **(a) USPTO Prosecution Documents.** Defendant caused Plaintiff's name to appear on more than 200 outgoing USPTO documents — including Filing Receipts, Office Actions, Notices of Allowance, Issue Notifications, and related correspondence — across at least 21 fully mapped patent applications. Each such document is a separate government record bearing Plaintiff's name as the responsible attorney. **(b) Client-Facing Correspondence.** Defendant, through employees acting under his direction and supervision, sent thousands of emails to clients attaching USPTO documents that listed "Richard C. Litman" as the attorney of record. Each such email constituted a separate publication of Plaintiff's name for commercial purposes. **(c) Law Firm Website.** Defendant's firm website (nathlaw.com) listed Plaintiff as "RICHARD C. LITMAN, PATENT ATTORNEY" — without any "Retired" designation — through at least June 21, 2025, as confirmed by archived website captures. **(d) Trademark Practice.** Plaintiff's name was used in connection with thousands of trademark-related client emails, continuing through at least August 2025. **(e) Third-Party Republication.** Each of the 905 patents was automatically indexed and republished by third-party patent databases including Google Patents, Espacenet, Justia Patents, and Lens.org, resulting in thousands of additional permanent, public publications of Plaintiff's name, all foreseeable consequences of Defendant's original USPTO filings. Plaintiff's investigation is ongoing and reserves the right to supplement this response. --- ### DEMAND NO. 2(a): Describe in detail how the use(s) identified above violate New York Civil Rights Law §§ 50-51. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff responds as follows: Each identified use constitutes the commercial use of Plaintiff's name in connection with professional legal services — securing and maintaining client relationships, representing clients before the USPTO, and advertising the firm — without Plaintiff's prior written consent, in violation of Sections 50-51. Defendant used Plaintiff's name as a commercial asset: to retain existing clients originated by Plaintiff, to attract new business through Plaintiff's reputation, and to represent the firm's capabilities to university and institutional clients in the Middle East and worldwide. No written consent was ever obtained. The Combination Agreement and its Amendment contain no provision authorizing the use of Plaintiff's personal name on government filings, client correspondence, or any other publications. Defendant's own Nunc Pro Tunc Assignment, recorded at the USPTO, states that "Assignee agrees that Assignor owns his name." --- ### DEMAND NO. 2(b): State with specificity every item of damage that was caused by the alleged use(s) of your name or likeness including the total amount you claim for each damage item. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff refers Defendant to the Response to Demand No. 1(b) and incorporates that response as if fully set forth herein. The same categories and bases of damages apply to all forms of unauthorized name use. --- ### DEMAND NO. 2(c): Describe in detail how the alleged use of your name on the identified patents caused each item of damage set forth above in subsection (b). **RESPONSE:** Subject to the foregoing General Objections, Plaintiff refers Defendant to the Response to Demand No. 1(c) and incorporates that response as if fully set forth herein. --- ### DEMAND NO. 3: Describe in detail the audience(s) for each alleged publication of your name or likeness that you allege evidence a violation of New York Civil Rights Law §§ 50-51 by Defendant. **RESPONSE:** Subject to the foregoing General Objections, Plaintiff responds as follows: The audiences for Defendant's unauthorized publications of Plaintiff's name include: **(a)** Current and prospective clients of the firm, including institutional assignees such as King Faisal University, King Saud University, Kuwait University, United Arab Emirates University, Dasman Diabetes Institute, and other Middle Eastern institutions and individual U.S. inventors. **(b)** United States Patent and Trademark Office examiners, officials, and administrative personnel who received and processed documents bearing Plaintiff's name. **(c)** Inventors, licensees, and prospective licensees who rely on the attorney of record identified on the patent face page. **(d)** The general public accessing USPTO records through the Patent Full-Text and Image Database, Patent Center, and related government databases. **(e)** Users of commercial patent databases and aggregators, including Google Patents, Espacenet, Justia Patents, Free Patents Online, Lens.org, and similar services that automatically index and republish USPTO patent records. **(f)** Professional contacts, prospective clients, and members of the public who viewed the nathlaw.com website listing Plaintiff as "PATENT ATTORNEY." --- Dated: New York, New York [DATE], 2026 WACHTEL MISSRY LLP By: ____________________________ Scott D. Woller, Esq. 885 Second Avenue, 47th Floor New York, New York 10017 (212) 909-9500 swoller@wmllp.com Attorneys for Plaintiff --- ## VERIFICATION STATE OF NEW YORK ) ) ss.: COUNTY OF KINGS ) RICHARD C. LITMAN, being duly sworn, deposes and says: I am the Plaintiff in this action. I have read the foregoing Verified Bill of Particulars and the contents thereof are true to my own knowledge, except as to matters stated to be upon information and belief, and as to those matters, I believe them to be true. ____________________________ Richard C. Litman Sworn to before me this ___ day of _______, 2026 ____________________________ Notary Public --- To: Leo J. Hurley, Jr., Esq. Aaron H. Gould, Esq. CONNELL FOLEY LLP 185 Hudson Street, Suite 2510 Jersey City, New Jersey 07311 (201) 521-1000 lhurley@connellfoley.com agould@connellfoley.com Attorneys for Defendant