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“Distinct”

and

“separate”

are

not

the

same

as

“independent.”

Moreover,

the

specification teaches that “separate manipulation” describes the user’s ability to work on

only

the

metacode

map

or

content.

Behind

the

scenes,

the

invention

keeps

the

metacode map and content synchronized. For example, Figure 9 teaches that updates

to the content may require the invention to make corresponding changes to the

metacode map. ’449 Patent col.14 l.49-col.15 l.5.

Microsoft is correct that the specification refers to working on “solely” the

document’s structure (metacode map):

The present invention provides the ability to work solely on metacodes. The process allows changes to be made to the structure of a document without requiring the content. A metacode map could be edited directly

without

the

mapped

content.

Additionally

a

new

map

can

be

created

based solely on an existing map without requiring the content.

Id. at col.7 ll.6-11 (emphases added). Read as a whole, however, these statements are

best understood as describing the advantages of separate storage, the real claim

limitation.

See

Abbott

Labs.,

566

F.3d

at

1289-90.

The

specification’s

permissive

language, “could be edited,” “can be created,” and “ability to work,” does not clearly

disclaim systems lacking these benefits.

An examination of the prosecution history similarly reveals no statements that

unequivocally

narrow

the

claims

to

require

independent

manipulation.

Initially,

the

examiner rejected several claims as obvious, explaining that “[s]torage is always

distinct, even if at distinct addresses.” In response, i4i stated:

[T]he architecture of a document can be treated as a separate entity from the content of the document. Thus, the architecture of the document can be treated as an entity having distinct storage from the content of the document. This separation allows distinct processes to operate on the content and the architecture, with or without knowledge of the other. In other words, using the present invention, one could change the

2009-1504

11

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