1. Load

   ~/.claude/plugins/config/claude-for-legal/litigation-legal/CLAUDE.md

   → role, work-product header, decision posture, document storage.
2. If matter workspaces enabled, confirm or select the active matter; load

   matter.md

   (side, jurisdiction, phase, theory, pleadings).
3. Follow the workflow and reference below.
4. Mode selection:

   • --patent

     → patent claim chart. Require patent number and at least one asserted claim. Sub-modes:

     --infringement

     ,

     --invalidity

     ,

     --review

     .

   • --civil

     → civil element chart. Require the cause of action (or defense) and the side.
   • No flag → ask the user which.
5. For civil mode: consult

   references/element-templates.md

   in the skill directory for the baseline element list. Confirm the controlling pattern instruction or statute with the user before mapping.
6. For patent mode: parse asserted claims into elements, flag disputed terms for construction, apply any Markman order.
7. Map elements against the target (accused product / prior art / evidence corpus / chart under review). Every cell pin-cited. Apply the apostrophe-prefix neutralization before writing any cell value starting with

   =

   ,

   +

   ,

   -

   ,

   @

   , tab, or CR.
8. Produce the gap list (civil) or needs-evidence list (patent) — the priority output.
9. Write markdown, CSV (values +

   _sources

   companion), and Excel or Sheets per user preference. Work-product header on every output.
10. Write to the matter's

    claim-charts/

    folder if a matter is active; otherwise the practice-level

    claim-charts/

    folder. Append a one-line entry to

    history.md

    if a matter is active.
11. Return a summary readout: claim(s), target(s), jurisdiction, phase, element counts by state, the gap list, file paths, and the reminder that every cell is a lead.

• England & Wales (CPR 31.22): Documents obtained through disclosure are subject to the implied undertaking — you may only use them for the purpose of the proceedings in which they were disclosed, unless the court grants permission, the disclosing party consents, or the document has been read in open court. Using them for a different matter, a different claim, or a commercial purpose without permission is a contempt.
• US: Protective orders and Rule 26(c) may impose similar restrictions. Check the order.
• Other jurisdictions: Similar restrictions commonly apply. Check the local rule.

This chart is a draft for attorney analysis and verification, not a filed contention, an MSJ brief, an opening statement, or a legal opinion. Every mapping is a lead the attorney must verify against the source. The elements listed come from pattern jury instructions, the Restatement, or the claim language as parsed — the controlling authority in the user's jurisdiction (CACI / NYPJI / the circuit's pattern charge / the governing statute / a Markman order) may differ and always controls. Gap detection is a starting point for discovery or a motion; it is not a conclusion about the merits.

• ~/.claude/plugins/config/claude-for-legal/litigation-legal/CLAUDE.md

  → role, work-product header, decision posture, document storage, case-theory scaffolding
• Active matter's

  matter.md

  — claims, defenses, side, jurisdiction, phase, theory
• For civil mode: the complaint or counterclaim (for the actually-pleaded counts), any answer (for the actually-pleaded affirmative defenses), the relevant pattern jury instruction source, and the governing statute if statutory. Also the evidence corpus — deposition transcripts, declarations, produced documents, expert reports.
• For patent mode: the patent, the asserted claims, the specification, prosecution history if available, the accused-product material or prior art reference, any Markman order or stipulated constructions.

CLAUDE.md

[PLACEHOLDER]

I notice you haven't configured your practice profile yet — that's how I tailor risk calibration, landscape, and house style to your practice.

Two choices:

• Run

  /litigation-legal:cold-start-interview

  (2 minutes) to configure your profile, then I'll run this tailored to YOUR practice.
• Say "provisional" and I'll run this against generic defaults — US jurisdiction, middle risk appetite, lawyer role, no playbook — and tag every output

  [PROVISIONAL — configure your profile for tailored output]

  so you can see what I do before committing.

[PROVISIONAL]

"That was a generic run against default assumptions. Run

/litigation-legal:cold-start-interview

to get output calibrated to YOUR practice — your risk calibration, your landscape, your house style. 2 minutes."

~/.claude/plugins/config/claude-for-legal/litigation-legal/matters/_log.yaml

_log.yaml

"I don't see [matter slug] in the matter log. Run

/litigation-legal:matter-intake

first so the conflicts check runs and the matter workspace is set up. I won't build a claim chart on a matter that hasn't been intaken — the conflicts check is the gate."

_log.yaml

Which kind of chart?

1. Patent claim chart — element-by-element mapping of claim limitations against an accused product (

   --infringement

   ), prior art (

   --invalidity

   ), or another party's chart (

   --review

   ). For patent contentions, IPR petitions / responses, FTO charts.
2. Civil element chart — elements of a cause of action (or affirmative defense) mapped against the evidence. For complaint plausibility checks, discovery planning, MSJ prep, order-of-proof outlines.

• Side. Asserting or defending? (In civil mode this flips the burden; in patent mode it flips infringement/invalidity framing.)
• Jurisdiction / forum. State and court — pattern instructions vary (CACI in California, NYPJI in New York, federal circuits' pattern charges, state-specific variations). In patent mode, Patent Local Rules vary (N.D. Cal., E.D. Tex., D. Del., ITC, PTAB). Flag which controls.
• Phase. Pre-filing, pleadings, discovery, MSJ, trial prep, post-trial. The chart is the same; the framing of the output changes.
• Existing chart? If

  --review

  , load it.

• --infringement

  — claim elements vs. accused product (PLR 3-1 infringement contentions, IPR/PGR response exhibits, complaint exhibits)

• --invalidity

  — claim elements vs. prior art (PLR 3-3 invalidity contentions, IPR/PGR petition exhibits, §102/§103 defenses)

• --review

  — audit a chart someone else produced

• Patent number and asserted claims. Which independent, which dependent. (Don't chart unasserted claims unless asked.)
• Priority date. Establishes the §102 bar and the effective filing date for the AIA / pre-AIA regime.
• Existing constructions. Markman order, stipulated constructions, constructions proposed in briefing.

• Preamble. Note whether it's limiting — a question of claim construction (Catalina Marketing Int'l, Inc. v. Coolsavings.com, Inc., 289 F.3d 801 (Fed. Cir. 2002)). Flag

  preamble-limiting: unresolved

  unless the construction order resolves it.
• Transitional phrase. "Comprising" (open) / "consisting of" (closed) / "consisting essentially of" (semi-open). Affects whether additional unrecited elements defeat infringement.
• Elements separated by commas / semicolons, numbered

  [1a]

  ,

  [1b]

  ,

  [1c]

  . Keep numbering stable — it's the chart's spine.
• Means-plus-function (§112(f)) — every "means for [function]" or non-structural functional term. Scope is the structure disclosed in the spec plus equivalents. Cite corresponding structure by col./line. If the spec fails to disclose structure, flag

  indefinite-112f

  .
• Markush groups, Jepson claims, product-by-process, method-step order dependencies — flag with a note on unusual construction rules.
• Dependent claims — reference parent; chart only the additional limitations. Execute, don't gesture. If asserted claims include dependents, produce the actual additional-limitation rows for each dependent in Step 4 — do not emit a note that dependents "should be charted."
• Structural-term cognates — default to

  construction-dependent

  . For each element that recites a structural noun with a common cognate in the prior art of the field, default the row's state to

  literal-construction-dependent

  (not

  literal

  ) unless the spec expressly defines the term or an existing Markman order forecloses the ambiguity. These are the terms most commonly disputed at Markman — presuming a clean literal read under-flags the risk. Common cognate families to flag proactively:

  Field	Cognate family (flag as structural-term-cognate )
  Fasteners / anchors	barb / thread / projection / ridge / fin / tooth
  Fluidics / catheters	lumen / channel / bore / passage / conduit
  Mechanical housings	hub / boss / flange / collar / shoulder
  Fasteners / joints	socket / recess / pocket / cavity
  Electrical / electronic	contact / terminal / pad / lead
  Optical	lens / reflector / window / aperture
  Structural	wall / member / support / strut / rib
  Surfaces	surface / face / interface

  This list is not exhaustive — if the claim recites a structural noun that could reasonably be read narrowly (pointed barb vs. any projection) or broadly (channel vs. any passage), flag

  structural-term-cognate

  in

  _constructions

  and default the row to

  construction-dependent

  . The attorney can demote it to

  literal

  after a Markman order or a definition in the spec forecloses the ambiguity.

• Coined terms or terms defined in the spec
• Terms with prosecution history (amendments, arguments, disavowals — Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005); Festo estoppel)
• Functional language ("configured to", "adapted to", "operable to")
• Relative terms ("substantially", "about") — definiteness risk under Nautilus, Inc. v. Biosig Instruments, Inc., 572 U.S. 898 (2014)
• Computer-implemented terms — Alice / §101 exposure for invalidity

1. Find evidence. Accused product: documentation, manuals, data sheets, source code, teardowns, deposition testimony, expert reports. Prior art: column/line for US patents, paragraph for published apps, page/figure for NPL. For prior art, flag whether the reference qualifies (§102(a)(1), (a)(2), (b); AIA vs. pre-AIA cutoffs). If prior-art status isn't obvious, mark

   prior-art-status: needs-evidence

   .
2. Quote verbatim. Character-for-character. No paraphrase. Cut at sentence boundaries and mark elision.
3. Characterize the mapping.

   Mapping	Meaning	Where
   literal	Claim language reads on the accused feature / prior-art disclosure	Both
   literal-construction-dependent	Literal under X; fails under Y	Both
   doe	Equivalent (function-way-result or insubstantial differences)	Infringement only
   anticipation	Every element in a single reference, arranged as claimed (Net MoneyIN, Inc. v. VeriSign, Inc., 545 F.3d 1359 (Fed. Cir. 2008))	Invalidity only
   obviousness-combination	Secondary reference supplies the missing element; motivation to combine required under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007)	Invalidity only
   partial	Some of the element is present	Both
   not-found	Element not present	Both
   needs-evidence	Can't tell from available material	Both
   construction-dependent	Turns on how a disputed term is construed	Both

4. State per cell.

   mapped

   /

   mapped-doe

   /

   partial

   /

   not-found

   /

   needs-evidence

   /

   construction-dependent

   /

   anticipation

   /

   obviousness-combination

   .
5. Flag open questions. "This maps if [X]. Need [teardown / source code / deposition / expert] to confirm."

needs-evidence

• Induced (§271(b)) — Commil USA, LLC v. Cisco Systems, Inc., 575 U.S. 632 (2015); Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011)
• Contributory (§271(c)) — component especially made for infringing use
• Divided / joint (§271(a)) — Akamai Techs., Inc. v. Limelight Networks, Inc., 797 F.3d 1020 (Fed. Cir. 2015) (en banc) directs/controls test
• Willfulness — Halo Elecs., Inc. v. Pulse Elecs., Inc., 579 U.S. 93 (2016); treble damages under §284

• §101 — Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208 (2014); Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012)
• §112 ¶ 1 — written description, enablement (Amgen Inc. v. Sanofi, 598 U.S. 594 (2023))
• §112 ¶ 2 — definiteness (Nautilus, supra)
• §112 ¶ 6 — means-plus-function structure
• Unenforceability — inequitable conduct, prosecution laches, assignor/licensee estoppel (attorney-only flags)

• Rule 11 / Patent Local Rule. Infringement and invalidity contentions require a reasonable inquiry and a non-frivolous basis. A chart out of this skill is a draft, not a contention.
• Claim construction candor. Every construction-dependent row states the construction assumed and the construction under which the mapping fails.
• DOE candor. A DOE mapping is not equivalent to a literal one. Flag prosecution history estoppel and dedication-to-the-public risks per element.
• Indirect is separate. Don't fold induced / contributory into direct-infringement rows.
• Invalidity burden on the chart. State the clear-and-convincing standard.

• What cause of action? (Or defense?) If multiple counts, chart each separately.
• Which side? Plaintiff's prima facie case, defendant's affirmative defense, defendant's challenge to plaintiff's prima facie case (MSJ mode). Read

  ## Side

  in the practice profile for the default —

  plaintiff

  defaults to mapping the prima facie case (proving the elements);

  defense

  defaults to mapping gaps and affirmative defenses (disproving or avoiding the elements). Confirm the posture matches this matter before starting.
• Which jurisdiction? State and court. Elements and pattern-instruction language vary by jurisdiction. The template library is a baseline; the controlling pattern instruction or statute controls.
• Which pleading? Load the complaint / counterclaim / answer so the chart tracks the counts actually pleaded, not a generic version.

references/element-templates.md

## Company profile → Core jurisdictions

matter.md

Jurisdiction note: You told me this is a [DE/NY/CA] matter. Here's how [jurisdiction]'s formulation differs from the baseline: [divergence]. The chart below uses the [jurisdiction] formulation. If that's wrong, say so and I'll reload.

• Evidence supporting — what proves this element? Cite the source with a pin cite.
  • Deposition testimony —

    [Doe Dep. 42:15–43:7]

  • Declaration —

    [Smith Decl. ¶ 12]

  • Produced document —

    [DEF00012345 at 3]

  • Admission —

    [Def.'s Resp. to RFA No. 5]

  • Exhibit —

    [Trial Ex. 14 at 2]

  • Expert report —

    [Jones Expert Rep. at 18]

  • Discovery response —

    [Pl.'s Resp. to Interrog. No. 8]

  • Statute / case — for purely legal elements
• Verbatim quote where the evidence is testimonial or documentary. No paraphrase.
• Evidence contradicting — what cuts the other way? Cite it. This is the row's vulnerability.
• Strength —

  strong

  /

  moderate

  /

  weak

  /

  none

  . Keep it simple. Over-calibrated strength scores are noise;

  weak

  and

  none

  are the rows that matter.
• State per cell —

  supported

  /

  partial

  /

  disputed

  /

  gap

  /

  needs-discovery

  .

Elements with thin or no evidence: [list]

• If asserting (plaintiff): these defeat your complaint's plausibility (Iqbal/Twombly), your MSJ opposition, or your case at trial. Close them before the next motion.
• If defending: these are your MSJ targets and your directed-verdict motion. The plaintiff has to prove each element; a gap is a defense.
• If pre-discovery: these are your discovery priorities — the depositions, document requests, and interrogatories that turn a gap into

  supported

  or confirm

  none

  .

• Pre-filing / pleadings. Does the complaint allege each element with plausibility (Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007))? Any element pleaded on information and belief without factual support is a 12(b)(6) target.
• Discovery. For each

  gap

  or

  needs-discovery

  element, what discovery is needed? Which witnesses, which document custodians, which interrogatories, which RFAs.
• MSJ. For each element, is there a genuine dispute of material fact? A

  supported

  cell for the movant with no contradicting evidence is summary-judgment ammunition; a

  disputed

  cell is MSJ-defeating.
• Trial. Order of proof. Which witness proves element 1, which exhibit proves element 2, who authenticates, what's the foundation. The chart becomes the trial outline.

• Jurisdiction. The element list is a baseline. Always confirm the controlling pattern instruction (CACI, NYPJI, federal circuit pattern charge, etc.) or statute. State the source on the chart's

  _elements

  sheet.
• Pleaded counts only. Chart what's actually pleaded. Don't add a count the complaint doesn't allege just because the facts might support it — that's a different analysis.
• Affirmative defenses. If mapping defenses, note whether the burden is on the defendant (most) or whether raising the defense shifts a burden to the plaintiff.
• "Gap" ≠ "case over." A gap is a lead. Discovery, a declaration, or an expert report can close it. The chart shows where to dig.

| [#] | Element (verbatim) | Accused feature | Evidence (pin-cited) | Mapping | State | Verified |
|---|---|---|---|---|---|---|
| 1a | "a processor configured to..." | SoC per datasheet | [Datasheet p. 7] "..." | literal-construction-dependent | mapped | ☐ |
| 1b | "means for [function]" (§112(f)) | [alleged equiv.] | [source, file.c:124] "..." | needs-evidence | needs-evidence | ☐ |

| [#] | Element | Evidence supporting (pin-cited) | Evidence contradicting | Strength | State | Verified |
|---|---|---|---|---|---|---|
| 1 | Existence of a contract | [Ex. 3, MSA § 1; Smith Dep. 22:4–14] | none | strong | supported | ☐ |
| 2 | Plaintiff's performance | [Jones Decl. ¶¶ 4–9] | [Doe Dep. 101:3–11: "they never delivered Phase 2"] | moderate | disputed | ☐ |
| 3 | Defendant's breach | — | [Doe Dep. 101:3–11] | none | gap | ☐ |
| 4 | Causation | — | — | none | needs-discovery | ☐ |
| 5 | Damages | [Expert Rep. at 18 — $2.4M lost profits] | [Def.'s Expert Rep. at 6 — critiques methodology] | moderate | disputed | ☐ |

• Defenses / thresholds (patent mode: invalidity / indirect / willfulness flags; civil mode: affirmative-defense flags, Iqbal/Twombly flags pre-pleading)
• Gap list (civil mode) / needs-evidence list (patent mode) — the priority output
• What cuts which way — summary — strongest elements, weakest elements
• Conclusion line — "This skill does not conclude." Elements mapped/supported: [list]. Elements needing evidence / in a gap state: [list]. Elements construction-dependent (patent) / disputed (civil): [list]. Attorney judgment required.
• Citation verification — every pin cite, case, column/line, deposition page:line must be verified against the source.

• [chart-slug].csv

  — values

• [chart-slug]_sources.csv

  — verbatim quotes, pin cites, notes

=

+

-

@

\t

\r

'

=HYPERLINK(...)

=cmd|...!A1

+WEBSERVICE(...)

=

corporate-legal

tabular-review

Verified

• One row per element (or element × target if comparing multiple targets)
• Each evidence column paired with a hidden source column containing the verbatim quote and pin cite; cell comments (Excel) or notes (Sheets) surface the quote on hover
• Color coding by state:
  • Patent: white =

    mapped

    , yellow =

    construction-dependent

    /

    partial

    / DOE, orange =

    needs-evidence

    , red =

    not-found

  • Civil: white =

    supported

    , yellow =

    partial

    /

    disputed

    , orange =

    needs-discovery

    , red =

    gap

• Verified

  column per evidence column, blank by default — reviewer marks it

• _elements

  sheet documenting the element source: pattern jury instruction (CACI No. X, NYPJI §Y, federal circuit pattern charge), statute (cite), Restatement section, or patent-claim parse. This is what makes the chart auditable — a reader can see where the elements came from.

• _gaps

  sheet listing every

  gap

  ,

  needs-evidence

  , or

  needs-discovery

  row with what's still needed
• For patent mode only:

  _claim-parse

  sheet (element decomposition),

  _constructions

  sheet (disputed terms and assumed constructions)

This chart is derived from source documents that may be privileged, confidential, or both. It inherits the sources' privilege and confidentiality status — distribution beyond the privilege circle can waive privilege. Store with the matter's privileged files and make distribution decisions deliberately. Nothing in this chart has been filed or served; it is a draft for attorney review.

• Patent infringement:

  claim-chart-infringement-[patent#]-claim[#]-[target]-YYYY-MM-DD.{md,csv,xlsx}

• Patent invalidity:

  claim-chart-invalidity-[patent#]-claim[#]-[ref]-YYYY-MM-DD.{md,csv,xlsx}

• Civil:

  element-chart-[count-slug]-[side]-YYYY-MM-DD.{md,csv,xlsx}

• Review:

  chart-review-[subject]-YYYY-MM-DD.{md,csv,xlsx}

~/.claude/plugins/config/claude-for-legal/litigation-legal/matters/<matter-slug>/claim-charts/

~/.claude/plugins/config/claude-for-legal/litigation-legal/claim-charts/

history.md

• Claim(s) / count(s) / patent claim(s), target(s), jurisdiction, phase
• Elements charted · supported/mapped · partial · disputed · gap / needs-evidence · not-found
• The gap list (civil) or needs-evidence list (patent) — this is the priority list
• Where the output files are
• Reminder: every cell is a lead. The chart is a draft, not a contention / brief / order of proof.

## Who's using this

This chart is a research draft, not a legal filing. Serving contentions, filing a brief, or relying on this for a merits opinion has Rule 11 and substantive legal consequences. An attorney in the relevant jurisdiction must review before this is used for any legal purpose.

Here's a one-page brief to bring to an attorney:

[Generate: claim / patent, side, jurisdiction, phase, elements, supported / gap / needs-discovery counts, the three most load-bearing open questions.]

• Citation verification. Every pin cite (column/line, page, deposition page:line, Bates, ¶) is a claim about the source. The attorney verifies. The skill does not fabricate cites — if a cite cannot be produced, the cell is

  needs-evidence

  or

  gap

  .
• Source attribution. Every verbatim quote has its source in the companion CSV and the spreadsheet's hidden source column. A quote without a source is not evidence.
• No silent supplement. Thin evidence means

  needs-evidence

  /

  gap

  , not "extrapolate." Do not fill from web search, training data, or "how these cases usually go" to close a gap.
• Matter workspace check. Confirm the active matter before writing. Never write matter A's chart into matter B's folder.
• Decision posture. When uncertain whether an element is met, flag; do not decide.

  partial

  tells the attorney what part is missing.
• Formula injection. Every cell written to CSV / XLSX / Sheets is checked for leading

  =

  ,

  +

  ,

  -

  ,

  @

  ,

  \t

  ,

  \r

  and prefixed with

  '

  . Default: neutralize-then-write.
• Elements are jurisdiction-specific. The template library is a baseline. The controlling pattern instruction or statute controls.
• A chart is not a brief, a filing, or a contention. Every output is a draft.

• ip-legal:infringement-triage

  (patent mode) — the first-pass flag list. This skill is the full chart that comes next.

• ip-legal:fto-triage

  — FTO uses the same mechanics from the potentially-accused posture. If evaluating own product vs. a third-party patent, route to FTO and use this skill's format.

• corporate-legal:tabular-review

  — the underlying cell-level citation and verification-state pattern. A claim / element chart is a specialized tabular review.

• litigation-legal:chronology

  — the chronology is the timeline; the element chart is the proof matrix. A chronology entry often becomes a cell's evidence cite.

• litigation-legal:deposition-prep

  — a

  needs-discovery

  cell often becomes a depo topic. After a depo, new testimony fills cells.

• litigation-legal:brief-section-drafter

  — an MSJ brief's fact section is often built directly off the supported rows of an element chart.

• It does not conclude. Not infringement, not non-infringement, not liability, not non-liability. Ever.
• It does not decide claim construction (patent) or the controlling elements (civil). It flags disputed terms / baseline elements and charts under stated assumptions.
• It does not meet the clear-and-convincing burden for invalidity or the preponderance at trial. It produces a prima facie draft for attorney review.
• It does not substitute for expert analysis. Source code review, teardowns, technical experts, damages experts are separate work products this chart routes to, not replaces.
• It does not serve, file, or sign anything. Every output is a draft. An attorney serves and files.
• It does not extrapolate. If the evidence isn't there, the cell is

  needs-evidence

  /

  gap

  — never a guess.