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Download: FINAL JUDGEMENT MEMORANDUM OPINION & ORDER.pdf
The technology in this case focuses on a particular type of electronic documents. Generally, a “document” as manifested in a computer program has two distinct parts: the content (i.e. the text that the user has created in the document) and the structure (the encoding that allows the computer to recognize the meaning of the text). A type of structural information within an electronic document sometimes comes in the form of “metacodes.” Standardized computer languages were developed that utilized metacodes to allow a computer to understand the meaning behind certain text that a user placed in a document. An early example of these languages is the Standard Generalized Markup Language (“SGML”). Later, a markup language was developed called the Extensible Markup Language (“XML”). Asserted U.S. Patent No. 5,787,449 (the “‘449 patent”) is entitled “Method and System for Manipulating the Architecture and the Content of a Document Separately from Each Other.” The ‘449 patented invention created a reliable method of processing and storing content and metacodes separately and distinctly. The data structure primarily responsible for this separation is called a “metacode map.” According to the patent, the “metacode map” allows a computer to manipulate the structure of a document without reference to the content.
Microsoft is the developer of popular word processing and editing software known as Word (“WORD”). Over the years, WORD has had many versions with increasing functionality. In 2003, Microsoft introduced a version of WORD with XML editing capabilities. This functionality continued in the latest version of WORD, “Word 2007.” On March 8, 2007 i4i LP filed this action alleging that Microsoft infringed the ‘449 patent. A jury trial commenced on May 11, 2009. At trial, i4i contended that Microsoft’s use of certain WORD 2003 and all of WORD 2007 products for processing XML documents with custom XML elements infringed claims 14, 18, and 20 of the ‘449 patent. i4i further argued that Microsoft’s infringement of the patent was willful. Microsoft claimed that its WORD products did not infringe the patent and that the patent was invalid. Following a seven day trial, the jury returned a verdict finding the patent valid and infringed and awarding i4i $200,000,000 in damages. The Court also conducted a bench trial regarding Microsoft's additional equitable defenses of laches and inequitable conduct.