DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
This Office action is in response to Amendments filed 3/30/2026.
Claim Rejections - 35 USC § 103
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claim(s) 1-3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park et al. (US 2007/0025226 A1) in view of Jeong et al. (US 2010/0240189 A1).
Regarding claim 1, Park discloses a semiconductor structure (Fig. 9) comprising:
a bottom electrode (“heating electrode 310”, ¶ 0043) including a plug (entirety of 310, see Fig. 9, this conforms with Applicant’s Specification which discloses that the bottom electrode and the metal plug are the same component; as 310 plugs the opening in 104, it is considered to be a plug), wherein the bottom electrode and the plug have substantially the same thickness (as they are the same component, they have the same thickness) and are in a same deposition layer in the semiconductor structure (as they are the same component, they are in the same deposition layer), and a recess is formed inside the metal plug (see Fig. 9); and
a memory cell (“phase change layer 112”, ¶ 0043), where a portion (portion within 310) of phase change material forming the memory cell is located within the recess formed inside the plug of the bottom electrode such that the portion of phase change material is in the same deposition layer as the bottom electrode and the plug (see Fig. 9).
Park differs from the claimed invention by the substitution of a metal for the plug with “any material that emits Joule heat by receiving a current” (¶ 0027). However, metal and the corresponding function was known in the art (¶ 0093 of Jeong). As such, it would have been obvious to one having ordinary skill in the art before the Application's effective filing date to have substituted the known material of metal as taught by Jeong for material of Park and the results of the substitution would have been predictable at emitting Joule heat by receiving a current. (see MPEP § 2143(I)(B)).
Regarding claim 2, Park in view of Jeong further discloses wherein the memory cell is a phase change memory cell (¶ 0041).
Regarding claim 3, Park in view of Jeong further discloses wherein the portion of the memory cell is a first portion of the memory cell, and the semiconductor structure further comprises:
a first layer (combination of 310 and the first portion of the memory cell) including the bottom electrode and the first portion of the memory cell;
a second layer (portion of 112 above 310) on top of the first layer, the second layer including a second portion (portion of 112 above 310) of the memory cell; and
a third layer (114) on top of the second layer, the third layer including a top electrode (“upper electrode 114”, ¶ 0043) connected to the memory cell.
Claim(s) 4-5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park and Jeong as applied to claim 3 and further in view of Lai et al. (US 9,537,093 B1).
Regarding claim 4, Park does not disclose the inclusion of a metal liner deposited on sidewalls of the second portion of the memory cell.
Lai, in the same field of endeavor, discloses forming a metal liner (“conductive spacers 216A, 216B” in Fig. 4B, Col. 4, Lines 16-17) on sidewalls of a memory cell (202).
There was a benefit to forming metal liners on the sidewalls of a memory cell in that is aids in providing stable resistance and stable operating efficiency (Col. 2, Lines 35-36 of Lai).
It would have been obvious to one having ordinary skill in the art before the Application's effective filing date to deposit the metal liner as taught by Lai on the sidewalls of the second portion of the memory cell of Park for this benefit.
Regarding claim 5, Park does not disclose that the second layer further comprises a first insulator and a second insulator, and the second portion of the memory cell is between the first insulator and the second insulator.
Lai, in the same field of endeavor, discloses forming a first insulator and a second insulator (insulating layers 240 in Figs. 6A and 6B) such that the memory cell is between the first insulator and the second insulator (see Fig. 6B).
There was a benefit to forming first and second insulators on either side of a memory cell in that it adds structural protection to the memory cell, reducing the risk of damage.
It would have been obvious to one having ordinary skill in the art before the Application's effective filing date to form a first insulator and a second insulator as taught by Lai in the second layer of Park such that the second portion of the memory cell is between the first insulator and the second insulator for this benefit.
Claim(s) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Park and Jeong as applied to claim 1 and further in view of Lai et al. (US 9,537,093 B1).
Regarding claim 6, Park does not disclose the inclusion of a metal liner deposited on sidewalls of the memory cell.
Lai, in the same field of endeavor, discloses forming a metal liner (“conductive spacers 216A, 216B” in Fig. 4B, Col. 4, Lines 16-17) on sidewalls of a memory cell (202).
There was a benefit to forming metal liners on the sidewalls of a memory cell in that is aids in providing stable resistance and stable operating efficiency (Col. 2, Lines 35-36 of Lai).
It would have been obvious to one having ordinary skill in the art before the Application's effective filing date to deposit the metal liner as taught by Lai on the sidewalls of the memory cell of Park for this benefit.
Response to Arguments
Applicant's arguments filed 3/30/2026 have been fully considered but they are not persuasive.
Applicant argues that “Park’s insulating layer 104 is an insulating layer, not a conductive layer. If Park’s insulating layer 104 is replaced by “metal as taught by Jeong”, as suggested by the Examiner, the resulting structure would have Park’s insulating layer 104 modified to a conducive layer”. This argument is not persuasive as the rejection did not suggest replacing layer 104 with a metal. Instead as discussed in the rejection, it would have been obvious to one having ordinary skill in the art at the time the application was filed to form component 310 of Park to be made of metal.
Applicant further argues that, “Even if the Examiner interpret Park’s insulating layer 104 as the metal plug recited in claim 1, Park’s insulating layer 104 does not have the same thickness as Park’s bottom electrode.” This argument is not persuasive as the rejection did not interpret Park’s insulating layer as the plug. Instead, component 310 is the plug, as discussed in the rejection. This is consistent with Applicant’s specification which sets forth that the bottom electrode is also the plug (see ¶ 0028 of Applicant’s Specification and Fig. 3).
Applicant further argues that “Park’s phase change layer 112 is not in the same deposition layer as Park’s bottom electrode” which Applicant has mapped as “Park’s bottom electrode 102”. This argument is not persuasive as it was not component 102 but, instead, heating electrode 310 which the rejection mapped as the bottom electrode of Park. As seen in Fig. 9 of Park, a portion of the phase change material forming the memory cell is located within the bottom electrode and is, there, in the same deposition layer a the bottom electrode.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/C.A.C/Examiner, Art Unit 2815
/JOSHUA BENITEZ ROSARIO/Supervisory Patent Examiner, Art Unit 2815
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