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information about the structure of electronic documents. After approximately four years,

the United States Patent and Trademark Office (“PTO”) allowed the application, which

issued as U.S. Patent No. 5,787,449 (“’449 patent”). The invention claimed in the ’449

patent forms the basis of this litigation. Since then, i4i has developed several software

products that practice the invention. One of these products is “add-on” software for

Microsoft Word, which expands Word’s capability to work with documents containing

custom XML.

XML is one of many markup languages. Markup languages tell the computer

how text should be processed by inserting “tags” around text. Tags give the computer

information about the text. For example, some tags might tell the computer how to

display text, such as what words should appear in bold or italics. Tags can also tell the

computer about the text’s content, identifying it as a person’s name or social security

number, for instance. Each tag consists of a delimiter and tag name. The delimiter sets

the tag apart from the content. Thus, a tag indicating that “717 Madison Pl. NW” is an

address might appear as <address>717 Madison Pl. NW</address> where “address” is

the tag’s name and “<” and “>” are the delimiters. Custom XML allows users to create

and define their own tags. i4i refers to tags and similar information about a document’s

structure as “metacodes.” The specification of the ’449 patent defines “metacode” as

“an individual instruction which controls the interpretation of the content of the data.”

’449 patent col.4 ll.15-16.

The ’449 patent claims an improved method for editing documents containing

markup

languages

like

XML.

The

improvement

stems

from

storing

a

document’s

content

and

metacodes

separately.

Id.

at

col.6

ll.18-21.

The

invention

primarily

2009-1504

3

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