achieves this separation by creating a “metacode map,” a data structure that stores the
metacodes and their locations within the document. The document’s content is stored
in a data structure called “mapped content.” Claim 14 is illustrative:
A method for producing a first map of metacodes and their addresses of use in association with mapped content and stored in distinct map storage means, the method comprising:
providing the mapped content to mapped content storage means;
providing a menu of metacodes; and
compiling a map of the metacodes in the distinct storage means, by locating, detecting and addressing the metacodes; and
providing the document as the content of the document and the metacode map of the document.
Id. at col.16 ll.18-30.
Separate storage of a document’s structure and content was an improvement
over prior technology in several respects. Importantly, it has allowed users to work
solely on a document’s content or its structure. Id. at col.7 ll.6-11, 17-20.
Since 2003, versions of Microsoft Word, a word processing and editing software,
have had XML editing capabilities. In 2007, i4i filed this action against Microsoft, the
developer and seller of Word. i4i alleged that Microsoft infringed claims 14, 18, and 20
of the ’449 patent by making, using, selling, offering to sell, and/or importing Word
Microsoft’s infringement was willful. Microsoft counterclaimed, seeking a declaratory
judgment that the ’449 patent was invalid and unenforceable.
Before the case was submitted to the jury, Microsoft moved for judgment as a
matter of law (“JMOL”) on the issues of infringement, willfulness, and validity. The