Prosecution Insights
Last updated: October 02, 2026
Application No. 17/797,333

CMP POLISHING LIQUID AND POLISHING METHOD

Non-Final OA §103
Filed
Aug 03, 2022
Priority
Feb 13, 2020 — JP PCT/JP2020/005602 +2 more
Examiner
LU, JIONG-PING
Art Unit
1713
Tech Center
1700 — Chemical & Materials Engineering
Assignee
RESONAC Corporation
OA Round
7 (Non-Final)
84%
Grant Probability
Favorable
7-8
OA Rounds
0m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allowance Rate
812 granted / 971 resolved
+18.6% vs TC avg
Moderate +8% lift
Without
With
+7.8%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 1m
Avg Prosecution
41 currently pending
Career history
1006
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
49.4%
+9.4% vs TC avg
§102
28.2%
-11.8% vs TC avg
§112
16.3%
-23.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 971 resolved cases

Office Action

§103
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 . In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office Action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on August 7, 2026 has been entered. Response to Amendments/Arguments Amendments made to claims 1, and 21-22, the cancelation of claims 2-20 and 23, and the addition of claims 24-40, as filed on August 7, 2026, are acknowledged. Applicant’s arguments with respect to amended claims 1, 21 and 22 have been considered but are moot because the arguments do not apply to new ground(s) of rejection in this Office Action necessitated by the amendments made to the claims. Election/Restrictions Newly submitted claims 31-32 are directed to an invention that is independent or distinct from the invention originally elected for prosecution, see the Office Action mailed on June 18, 2024 for more details. Since the Applicant has received an action on the merits for the originally presented invention, this invention has been constructively elected by original presentation for prosecution on the merits. Accordingly, claims 31-32 are withdrawn from consideration as being directed to a non-elected invention. See 37 CFR 1.142(b) and MPEP § 821.03. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office Action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102 of this title, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 1, 22, 24-30 and 35 are rejected under 35 U.S.C. 103 as being unpatentable over Brosnan et al. (US20190284434) in view of Masato et al. (JP2017139350, a machine-translated English version is used) and Shin et al. (KR20200062732, a machine-translated English version is used). Regarding claim 1, Brosnan discloses a CMP polishing liquid (paragraph 0008) comprising: abrasive grains (paragraph 0008); and a cationic polymer (paragraph 0008), wherein the abrasive grains contain a cerium-based compound (ceria, paragraph 0009), the cationic polymer has a main chain containing a nitrogen atom and a carbon atom and a hydroxyl group bonded to the carbon atom, the cationic polymer contains a reaction product of a raw material containing at least dimethylamine and epichlorohydrin [poly(dimethylamine-co-epichlorohydrin), paragraph 0016], a weight average molecular weight of the cationic polymer is 10000 to 525000 (paragraph 0018), and a pH is less than 6.0 (about 3.5, paragraph 0040). Brosnan is silent about the cationic polymer contains a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin; however, Brosnan discloses that the polishing liquid comprises one or more cationic polymers, including cationic co-polymers such as poly(diallyldimethylammonium chloride) and poly(dimethylamine-co-epichlorohydrin) (paragraph 0016). In addition, Masato teaches that examples of cationic polymers used in a polishing liquid include diallyldimethylammonium salt polymer and a cationic polymer containing a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin (condensates of dimethylamine, ammonia, and epichlorohydrin, paragraph 0054). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known cationic polymer for a polishing composition, such as a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin, as taught by Masato in the composition of Brosnan, with a reasonable expectation of success. It has been held that substituting equivalents known for the same purpose is obvious. See MPEP 2144.06 II. Brosnan in view of Masato is silent about the polishing liquid comprising at least one cyclic compound selected from the group consisting of an amino group-containing aromatic compound and a nitrogen-containing heterocyclic compound, wherein the nitrogen-containing heterocyclic compound includes at least one selected from the group consisting of pyridinecarboxylic acid, pyridinyl ketone, and pyridinyl carboxamide, the pyridinecarboxylic acid includes at least one selected from the group consisting of 3-pyridinecarboxylic acid and 4-pyridinecarboxylic acid. However, Brosnan discloses that the polishing liquid comprises a dispersant (paragraph 0037). In addition, Shin teaches that nicotinic acid (3-pyridinecarboxylic acid) and isonicotinic acid (4-pyridinecarboxylic acid) are among known dispersants for a polishing liquid comprising ceria abrasive (paragraphs 0008-0009 and 0011). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known dispersant, such as nicotinic acid (3-pyridinecarboxylic acid) or isonicotinic acid (4-pyridinecarboxylic acid), as taught by Shin, in the polishing liquid of Brosnan in view of Masato, with a reasonable expectation of success. It has been held that combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2143 I.(A). Regarding claim 22, Brosnan discloses a CMP polishing liquid (paragraph 0008) comprising: abrasive grains (paragraph 0008); and a cationic polymer (paragraph 0008), wherein the abrasive grains contain a cerium-based compound (ceria, paragraph 0009), the cationic polymer has a main chain containing a nitrogen atom and a carbon atom and a hydroxyl group bonded to the carbon atom, the cationic polymer contains a reaction product of a raw material containing at least dimethylamine and epichlorohydrin [poly(dimethylamine-co-epichlorohydrin), paragraph 0016], and a pH is about 3.5 (paragraph 0040). Brosnan is silent about the cationic polymer contains a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin; however, Brosnan discloses that the polishing liquid comprises one or more cationic polymers, including cationic co-polymers such as poly(diallyldimethylammonium chloride) and poly(dimethylamine-co-epichlorohydrin) (paragraph 0016). In addition, Masato teaches that examples of cationic polymers used in a polishing liquid include diallyldimethylammonium salt polymer and a cationic polymer containing a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin (condensates of dimethylamine, ammonia, and epichlorohydrin, paragraph 0054). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known cationic polymer for a polishing composition, such as a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin, as taught by Masato in the composition of Brosnan, with a reasonable expectation of success. It has been held that substituting equivalents known for the same purpose is obvious. See MPEP 2144.06 II. Brosnan in view of Masato is silent about the polishing liquid comprising at least one cyclic compound selected from the group consisting of an amino group-containing aromatic compound and a nitrogen-containing heterocyclic compound, wherein the nitrogen-containing heterocyclic compound includes at least one selected from the group consisting of pyridinecarboxylic acid, pyridinyl ketone, and pyridinyl carboxamide, the pyridinecarboxylic acid includes at least one selected from the group consisting of 3-pyridinecarboxylic acid and 4-pyridinecarboxylic acid. However, Brosnan discloses that the polishing liquid comprises a dispersant (paragraph 0037). In addition, Shin teaches that nicotinic acid (3-pyridinecarboxylic acid) and isonicotinic acid (4-pyridinecarboxylic acid) are among known dispersant for a polishing liquid comprising ceria abrasive (paragraphs 0008-0009 and 0011). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known dispersant, such as nicotinic acid (3-pyridinecarboxylic acid) or isonicotinic acid (4-pyridinecarboxylic acid), as taught by Shin, in the polishing liquid of Brosnan in view of Masato, with a reasonable expectation of success. It has been held that combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2143 I.(A). Regarding claim 24, Brosnan discloses wherein the content of the cationic polymer is 0.005 parts by mass or more and less than 0.025 parts by mass with respect to 100 parts by mass of the CMP polishing liquid (5ppm to 250ppm, paragraph 0019). Regarding claim 25, Brosnan discloses wherein the cerium-based compound is cerium oxide (ceria, paragraph 0009). Regarding claim 26, Brosnan discloses wherein a content of the abrasive grains is 0.01 to 7 parts by mass with respect to 100 parts by mass of the CMP polishing liquid (paragraph 0015). Regarding claim 27, Shin discloses wherein a content of the cyclic compound is 0.01 to 5 part by mass with respect to 100 parts by mass of the CMP polishing liquid (paragraph 0011), which overlaps with the range recited in the instant claim. In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). MPEP 2144.05(I). Regarding claim 28, Brosnan discloses wherein a pH is about 3.5 (paragraph 0040). Regarding claim 29, Brosnan discloses wherein the CMP polishing liquid is used for polishing an insulating material (a dielectric material, paragraph 0052). Regarding claim 30, Brosnan discloses wherein the insulating material contains silicon oxide (paragraph 0052). Regarding claim 35, Shin discloses wherein the cyclic compound includes 3-pyridinecarboxylic acid (nicotinic acid, paragraph 0011). Claim 21 is rejected under 35 U.S.C. 103 as being unpatentable over Brosnan et al. (US20190284434) in view of Shin et al. (KR20200062732, a machine-translated English version is used). Regarding claim 21, Brosnan discloses a CMP polishing liquid (paragraph 0008) comprising: abrasive grains (paragraph 0008); and a cationic polymer (paragraph 0008), wherein the cationic polymer has a main chain containing a nitrogen atom and a carbon atom and a hydroxyl group bonded to the carbon atom [poly(dimethylamine-co-epichlorohydrin), paragraph 0016], a content of the cationic polymer is 0.0005 parts by mass or more and less than 0.025 parts by mass with respect to 100 parts by mass of the CMP polishing liquid (paragraph 0066), a weight average molecular weight of the cationic polymer is 10000 to 525000 (paragraph 0018), and a pH is less than 4.0 (about 3.5, paragraph 0040). The concentration range of the cationic polymer disclosed by Brosnan overlaps with the range recited in the instant claim. In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). MPEP 2144.05(I). Brosnan is silent about the polishing liquid comprising a nitrogen-containing heterocyclic compound, wherein the nitrogen-containing heterocyclic compound includes at least one selected from the group consisting of pyridinecarboxylic acid, pyridinyl ketone, and pyridinyl carboxamide, the pyridinecarboxylic acid includes at least one selected from the group consisting of 3-pyridinecarboxylic acid and 4-pyridinecarboxylic acid. However, Brosnan discloses that the polishing liquid comprises a dispersant (paragraph 0037). In addition, Shin teaches that nicotinic acid (3-pyridinecarboxylic acid) and isonicotinic acid (4-pyridinecarboxylic acid) are among known dispersant for a polishing liquid comprising ceria abrasive (paragraphs 0008-0009 and 0011). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known dispersant, such as nicotinic acid (3-pyridinecarboxylic acid) or isonicotinic acid (4-pyridinecarboxylic acid), as taught by Shin, in the polishing liquid of Brosnan in view of Masato, with a reasonable expectation of success. It has been held that combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2143 I.(A). Claims 22 and 33-34 are rejected under 35 U.S.C. 103 as being unpatentable over Brosnan et al. (US20190284434) in view of Masato et al. (JP2017139350, a machine-translated English version is used) and Jung et al. (KR20140059328, a machine-translated English version is used). Regarding claim 22, Brosnan discloses a CMP polishing liquid (paragraph 0008) comprising: abrasive grains (paragraph 0008); and a cationic polymer (paragraph 0008), wherein the abrasive grains contain a cerium-based compound (ceria, paragraph 0009), the cationic polymer has a main chain containing a nitrogen atom and a carbon atom and a hydroxyl group bonded to the carbon atom, the cationic polymer contains a reaction product of a raw material containing at least dimethylamine and epichlorohydrin [poly(dimethylamine-co-epichlorohydrin), paragraph 0016], and a pH is about 3.5 (paragraph 0040). Brosnan is silent about the cationic polymer contains a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin; however, Brosnan discloses that the polishing liquid comprises one or more cationic polymers, including cationic co-polymers such as poly(diallyldimethylammonium chloride) and poly(dimethylamine-co-epichlorohydrin) (paragraph 0016). In addition, Masato teaches that examples of cationic polymers used in a polishing liquid include diallyldimethylammonium salt polymer and a cationic polymer containing a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin (condensates of dimethylamine, ammonia, and epichlorohydrin, paragraph 0054). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known cationic polymer for a polishing composition, such as a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin, as taught by Masato in the composition of Brosnan, with a reasonable expectation of success. It has been held that substituting equivalents known for the same purpose is obvious. See MPEP 2144.06 II. Brosnan in view of Masato is silent about the polishing liquid comprising at least one cyclic compound selected from the group consisting of an amino group-containing aromatic compound and a nitrogen-containing heterocyclic compound. However, Brosnan discloses that the polishing liquid comprises a dispersant (paragraph 0037). In addition, Jung teaches that aminobenzoic acid (an amino group-containing aromatic compound) is a known dispersant for a polishing liquid comprising ceria abrasive (paragraphs 0034 and 0043). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use known dispersant, such as aminobenzoic acid, as taught by Jung, in the polishing liquid of Brosnan in view of Masato, with a reasonable expectation of success. It has been held that combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2143 I.(A). Regarding claim 33, Jung discloses wherein the cyclic compound includes the amino group-containing aromatic compound (aminobenzoic acid, paragraph 0043). Regarding claim 34, Jung discloses wherein the cyclic compound includes an aminobenzoic acid (paragraph 0043). Claim 40 is rejected under 35 U.S.C. 103 as being unpatentable over Brosnan et al. (US20190284434) in view of Masato et al. (JP2017139350, a machine-translated English version is used) and Satou et al. (US20110275285). Regarding claim 40, Brosnan discloses a CMP polishing liquid (paragraph 0008) comprising: abrasive grains (paragraph 0008); and a cationic polymer (paragraph 0008), wherein the abrasive grains contain a cerium-based compound (ceria, paragraph 0009), the cationic polymer has a main chain containing a nitrogen atom and a carbon atom and a hydroxyl group bonded to the carbon atom, the cationic polymer contains a reaction product of a raw material containing at least dimethylamine and epichlorohydrin [poly(dimethylamine-co-epichlorohydrin), paragraph 0016], and a pH is about 3.5 (paragraph 0040). Brosnan is silent about the cationic polymer contains a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin; however, Brosnan discloses that the polishing liquid comprises one or more cationic polymers, including cationic co-polymers such as poly(diallyldimethylammonium chloride) and poly(dimethylamine-co-epichlorohydrin) (paragraph 0016). In addition, Masato teaches that examples of cationic polymers used in a polishing liquid include diallyldimethylammonium salt polymer and a cationic polymer containing a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin (condensates of dimethylamine, ammonia, and epichlorohydrin, paragraph 0054). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known cationic polymer for a polishing composition, such as a reaction product of a raw material containing at least dimethylamine, ammonia, and epichlorohydrin, as taught by Masato in the composition of Brosnan, with a reasonable expectation of success. It has been held that substituting equivalents known for the same purpose is obvious. See MPEP 2144.06 II. Brosnan in view of Masato is silent about the polishing liquid comprising salicyllaldoxime. However, Brosnan discloses that the polishing liquid comprises a rate enhancer (paragraph 0037) and is used for polishing silicon oxide in STI application (paragraphs 0003 and 0052). In addition, Satou teaches that salicylaldoxime is a polish rate enhancer for polishing silicon oxide (paragraphs 0008 and 0028). Therefore, it would have been obvious to one of ordinary skill, in the art before the effective filing date of the claimed invention, to use a known rate enhancer, such as salicylaldoxime, as taught by Satou, in the polishing liquid of Brosnan in view of Masato, with a reasonable expectation of success. It has been held that combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2143 I.(A). Allowable Subject Matter Claims 36-39 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: Regarding claim 36, the cited prior art of record, taken either alone or in combination, fails to disclose or render obvious a polishing liquid wherein the cyclic compound includes the pyridinyl ketone, in the context of the instant claim. Regarding claim 37, the cited prior art of record, taken either alone or in combination, fails to disclose or render obvious a polishing liquid wherein the cyclic compound includes 1-(2-pyridinyl)-1-ethanone, in the context of the instant claim. Regarding claim 38, the cited prior art of record, taken either alone or in combination, fails to disclose or render obvious a polishing liquid wherein the cyclic compound includes the pyridinyl carboxamide, in the context of the instant claim. Regarding claim 39, the cited prior art of record, taken either alone or in combination, fails to disclose or render obvious a polishing liquid wherein the cyclic compound includes pyridine-3-carboxamide, in the context of the instant claim. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JIONG-PING LU whose telephone number is (571) 270-1135. The examiner can normally be reached on M-F: 9:00am – 5:00pm. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Joshua L Allen, can be reached at telephone number (571)270-3176. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from Patent Center. Status information for published applications may be obtained from Patent Center. Status information for unpublished applications is available through Patent Center for authorized users only. Should you have questions about access to Patent Center, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) Form at https://www.uspto.gov/patents/uspto-automated- interview-request-air-form. /JIONG-PING LU/ Primary Examiner, Art Unit 1713
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Prosecution Timeline

Show 11 earlier events
Dec 02, 2025
Non-Final Rejection mailed — §103
Mar 02, 2026
Response Filed
Apr 07, 2026
Final Rejection mailed — §103
Jul 13, 2026
Examiner Interview Summary
Jul 13, 2026
Applicant Interview (Telephonic)
Aug 07, 2026
Request for Continued Examination
Aug 10, 2026
Response after Non-Final Action
Sep 08, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

7-8
Expected OA Rounds
84%
Grant Probability
91%
With Interview (+7.8%)
2y 1m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 971 resolved cases by this examiner. Grant probability derived from career allowance rate.

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