Prosecution Insights
Last updated: July 17, 2026
Application No. 17/833,208

Semiconductor Device and Method Forming Same

Non-Final OA §103
Filed
Jun 06, 2022
Examiner
BULLARD-CONNOR, GENEVIEVE GRACE
Art Unit
2899
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Taiwan Semiconductor Manufacturing Company, Ltd.
OA Round
3 (Non-Final)
50%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 50% of resolved cases
50%
Career Allowance Rate
7 granted / 14 resolved
-18.0% vs TC avg
Strong +47% interview lift
Without
With
+46.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
38 currently pending
Career history
72
Total Applications
across all art units

Statute-Specific Performance

§103
85.2%
+45.2% vs TC avg
§102
11.4%
-28.6% vs TC avg
§112
3.4%
-36.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 14 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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 March 3 2026 has been entered. 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, 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. Claims 1-7, 21, 23-24, 27-31, and 33 are rejected under 35 U.S.C. 103 as being unpatentable over Shah et al. (“Shah” US 2022/0199429), Osenbach et al. (“Osenbach” US 2022/0216127), and Rawlings et al. (“Rawlings” US 2019/0393118). Regarding claim 1, Shah discloses a method of manufacturing a semiconductor device (Figures 2B, 4), comprising: adhering a first Thermal Interface Material (TIM) (202) over a first portion of a first package (chips 102/204, here the first portion is considered as the perimeter of the upper surfaces of the chips 102/104); dispensing a second TIM (110) over a second portion of the first package (102/204, here the second portion is considered the inner region of the chips’ upper surfaces); initiating an initial cross-linking of the first TIM (202) by curing the first TIM (202) after the dispensing the second TIM (110, see Figure 4 which shows the TIMs, “stiffening adhesive” 202 and TIM 110, being places on the chip prior to curing the “stiffening adhesive” TIM 202, see step 408, thus the TIM 202 undergoes an initial cross-linking due to the curing step, see also para. [0032]); and attaching a heat sink (lid 106) to the first TIM (202, see Figure 2B, para. [0033]). Shah does not disclose that the first TIM is formed from a phase-change material. Osenbach discloses, however, a “containment ring” (102a) analogous to the claimed first TIM that is formed from a phase-change material (see para. [0080]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Osenbach into the teachings of Shah to include a phase-change material for the first TIM for the purpose of utilizing a material with higher strength (see Osenbach, para. [0080]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Shah and Osenbach do not disclose that the second TIM is formed from a liquid metal. Rawlings discloses, however, a second TIM (109) formed from a liquid metal (109, para. [0016]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Rawlings into the teachings of Shah and Osenbach to include that the second TIM is formed from a liquid metal for the purpose of increasing compliance to warping (para. [0013]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Regarding claim 2, Shah discloses wherein the first TIM (202) covers an exterior area of the first package (102/204, see Figure 2B) and the second TIM (110) covers an interior area of the first package (102/204, see Figure 2B). Regarding claim 3, Shah further discloses forming a first strip (strip of first TIM 202 on the right side of the left sided die 102) of the first TIM (202) that bisects the first package (102/204, the strip of the first TIM 202 on the right side of the left sided chip 102 essentially bisects the package 102/204 into two parts), wherein the second portion (inner regions of upper surfaces of the chips 102/205) further comprises a first isolated region (inner upper surface of the left sided die 102) and a second isolated region (inner upper surface of the right sided die 204, see Figure 2B). Regarding claim 4, Shah discloses wherein the first TIM (202) covers a perimeter of a die (chip 102, see Figure 2B) in the first package (102/204) and the second TIM (110) covers a first isolated area (area on the top surface of die 204) outside the first TIM (202, a portion of the second TIM 110 is located outside the first TIM 202 that covers the die 102, since a portion of the second TIM 110 is also placed on the other die 204) and a second isolated area (area on the top surface of die 102) inside the first TIM (202, see the first TIM 202 on the die 102 within which a portion of the second TIM 110 is place, thus is also located in a second isolated area inside the first TIM 202 on die 102). Regarding claim 5, Shah discloses wherein the attaching the heat sink (106) to the first TIM (202) spreads the liquid metal (incorporated into the second TIM 110 by Rawlings) across the second portion (inner region of the chips’ 102/204 upper surfaces) of the first package (102/204, para. [0029] discloses that the application of the lid 106 will cause a degree of spreading of the first TIM 202, thus it would be obvious to a person having ordinary skill in the art that the application of the lid, since the lid is placed after the placement of the second TIM 110, would also spread the second TIM across the upper surfaces of the package). Regarding claim 6, The combination of Shah, Osenbach, and Rawlings further discloses cross-linking the first TIM (202) to form a cross-linked gel (Shah discloses curing the first TIM 202, the materials of the TIMs incorporated by Osenbach and Rawlings, thus resulting in a cross-linked gel material). Shah does not explicitly disclose a cross-linked gel. However, the instant specification does not provide any mechanism by which the cross-linking is formed other than a curing process, which Shah discloses (see para. [0034]). Therefore, a person of ordinary skill in the art would expect that, as Shah provides the disclosed method and Rawlings and Osenbach provide the TIM materials (phase change material and liquid metal), the cross-linking of the first TIM (202) by curing, a cross-linked gel would also have formed. Regarding claim 7, The combination of Shah, Osenbach, and Rawlings further discloses cross-linking the first TIM with the second TIM to form a cross-linked product at an interface between the first TIM and the second TIM. Shah does not explicitly disclose a cross-linked interface. However, the instant specification does not provide any mechanism by which the cross-linked interface is formed other than a curing process, which Shah discloses (para. [0034]). Therefore, a person of ordinary skill in the art would expect that, as Shah provides the curing method and Rawlings and Osenbach provide the TIM materials, the cross-linking of the first TIM and second TIM would also have occurred. Regarding claim 21, Shah discloses a method of manufacturing a semiconductor device (Figures 2A, 4) comprising: bonding a package component (chip 102) to a package substrate (104, see Figure 2A, para. [0022]); dispensing a boundary layer (202) on a perimeter of a first top surface of the package component (102, see Figure 2A), wherein during the dispensing a material of the boundary layer (202) has a first amount of cross- linking (the material of the boundary layer itself 202 would have a certain amount of cross-linking in its pre-cured form); dispensing a [material] (110) onto the package component (102) within the perimeter (see Figure 2A); placing a heat sink (106) in contact with the boundary layer (202) and the [material] (110, see Figure 2A); performing a clamping process, the clamping process comprising pressing the heat sink (106) towards the package substrate (104, since the process disclosed by Shah describes the heat sink 106 being applied to the package component and the boundary layer causes a degree of spreading of the boundary layer 202, see para. [0029], thus it is obvious to a person having ordinary skill in the art that the application of the lid comprises pressing the lid towards the package substrate); and after the performing the clamping process (406, see Figure 4), curing the boundary layer (202, para. [0034]) to increase cross-linking in the material of the boundary layer (202) from the first amount (amount during dispensing of the boundary layer 202) to a second amount (an increased amount, since the boundary layer 202 is hardened during the curing process), wherein after the curing the boundary layer (202) is solidified (see para. [0034]). Shah does not disclose that the boundary layer comprises a phase-change material. Osenbach discloses, however, a “containment ring” (102a) analogous to the claimed boundary layer that comprises a phase-change material (see para. [0080]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Osenbach into the teachings of Shah to include a phase-change material for the boundary layer for the purpose of utilizing a material with higher strength (see Osenbach, para. [0080]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Shah and Osenbach not disclose that the material dispensed onto the package component within the perimeter is a liquid metal. Rawlings discloses, however, a thermal interface material (109), analogous to the “material” 110 of Shah above, formed from a liquid metal (109, para. [0016]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Rawlings into the teachings of Shah and Osenbach to include that the material 110 of Shah is formed from a liquid metal for the purpose of increasing compliance to warping (para. [0013]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Regarding claim 23, The combination of Shah, Osenbach, and Rawlings discloses wherein the performing the clamping process spreads the liquid metal (liquid metal incorporated by Osenbach into TIM 110 of Shah, para. [0029] discloses that the application of the lid 106, or the pressing process of clamping, will cause a degree of spreading of the boundary layer 202, thus it would be obvious to a person having ordinary skill in the art that the application of the lid, since the lid is placed after the placement of the material 110, would also spread the material 110 across the upper surfaces of the chip 102), the boundary layer (202) keeping the liquid metal (110, liquid metal material incorporated by Rawlings) within the perimeter (see para. [0032] and Figure 2A, the boundary layer 202 frames the material 110). Regarding claim 24, The combination of Shah, Osenbach, and Rawlings discloses wherein after the clamping process (Figure 4, 406) the liquid metal (110, liquid metal material incorporated by Rawlings) has a second top surface that is planar with a bottom surface of the heat sink (106, finished product of Figure 2A after the clamping/pressing/application of the lid 106 shows the surfaces coplanar with each other). Regarding claim 27, Shah discloses a method of manufacturing a semiconductor device (Figures 2B, 4), the method comprising: forming a boundary layer (202) on a perimeter of a first top surface of a package component (102, see Figure 2B); dispensing a [material] (110) onto the package component (102) within the perimeter (see Figure 2B, para. [0032]); placing a heat sink (106) in contact with the boundary layer (202) and the [material] (110, see Figure 2B); and beginning a cross-linking by curing (Figure 4, 408, para. [0034]) the boundary layer (202) after the placing the heat sink (106, see flow chart of order of processing steps in Figure 4, which shows the curing occurring after the placement of the heat sink, 406), wherein at a beginning of the cross-linking, the boundary layer (202) is cross-linked a substantially similar amount as during the dispensing (since the boundary layer 202 is unaltered further after dispensing until the only curing process, 408, it is obvious that the degree of cross-linking of the boundary layer 202 would substantially be the same since dispensing). Shah does not disclose that the boundary layer comprises a phase-change material. Osenbach discloses, however, a “containment ring” (102a) analogous to the claimed boundary layer that comprises a phase-change material (see para. [0080]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Osenbach into the teachings of Shah to include a phase-change material for the boundary layer for the purpose of utilizing a material with higher strength (see Osenbach, para. [0080]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Shah and Osenbach do not disclose that the material dispensed onto the package component within the perimeter is a liquid metal. Rawlings discloses, however, a thermal interface material (109), analogous to the “material” 110 of Shah above, formed from a liquid metal (109, para. [0016]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Rawlings into the teachings of Shah and Osenbach to include that the material 110 of Shah is formed from a liquid metal for the purpose of increasing compliance to warping (para. [0013]). Additionally, the selection of a known material based on its suitability for its intended use is prima facie obvious. See MPEP 2144.07. Regarding claim 28, Shah discloses wherein after the curing (408) the boundary layer (202) is solidified (see para. [0034]). Regarding claim 29, The combination of Shah, Osenbach, and Rawlings discloses wherein a cross-linked gel is formed at an interface between the boundary layer (202) and the liquid metal (110, liquid metal material incorporated by Rawlings). Shah does not explicitly disclose a cross-linked gel at the interface of elements 202/110. However, the instant specification does not provide any mechanism by which the cross-linked interface is formed other than a curing process, which Shah discloses (para. [0034]). Therefore, a person of ordinary skill in the art would expect that, as Shah provides the curing method and Rawlings and Osenbach provide the phase change and liquid materials, the cross-linking of the boundary layer and the liquid metal would also have occurred. Regarding claim 30, The combination of Shah, Osenbach, and Rawlings discloses wherein the liquid metal (110, liquid metal material incorporated by Rawlings) contacts the boundary layer (202) after placing the heat sink (106) in contact with the boundary layer (202, see Figure 2B which shows the contact between the material 110 and boundary layer 202). Regarding claim 31, The combination of Shah, Osenbach, and Rawlings discloses wherein after placing the heat sink (106, Figure 2B), a top surface of the liquid metal (110, liquid metal material incorporated by Rawlings ) is level with a top surface of the boundary layer (202, see Figure 2B). Regarding claim 33, Shah discloses wherein the liquid metal (110, liquid metal material incorporated by Rawlings) is split into two or more isolated regions (see region of 110 over chip 102, and another portion of material 110 over chip 204, thus is split into two or more isolated regions). Claims 22, 25, and 32 are rejected under 35 U.S.C. 103 as being unpatentable over Shah, Osenbach, and Rawlings as applied to claim 21 and 27 above, and further in view of Honeywell (Honeywell Portfolio of Products, Brochure, August 2021). Regarding claim 22, the combinations of teachings of Shah, Osenbach, and Rawlings do not disclose that the boundary layer has a glass- transition temperature between about 45 °C and about 60 °C. Honeywell discloses a phase-change material, analogous to the boundary layer of the combination of teachings above, has a glass- transition temperature between about 45 °C and about 60 °C (page 7 discloses that the phase change temperature is 45°C). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Honeywell into the teachings of Shah, Osenbach, and Rawlings to include wherein the boundary layer has a glass- transition temperature between about 45 °C and about 60 °C to provide optimal surface wetting at manufacturing temperatures (Honeywell, page 7). Regarding claim 25, the combinations of teachings of Shah, Osenbach, and Rawlings do not disclose wherein the phase-change material has a melting point above 40 °C. Honeywell discloses wherein the phase-change material has a melting point above 40 °C (PCM has a phase change temperature of 45°C, page 7). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Honeywell into the teachings of Shah, Osenbach, and Rawlings to include wherein the boundary layer has a glass- transition temperature between about 45 °C and about 60 °C to provide optimal surface wetting at manufacturing temperatures (Honeywell, page 7). Regarding claim 32, the combinations of teachings of Shah, Osenbach, and Rawlings do not disclose wherein the phase-change material has a thermal conductivity value of about 5 W/mk or greater and a Young's modulus value of about 10 MPa or less. Honeywell discloses wherein the phase-change material (page 7) has a thermal conductivity value of about 5 W/mk or greater (page 7 discloses a thermal conductivity of 6.0-8.5 W/mK). It would have been obvious to one having ordinary skill in the art before the effective filing date of the present invention to incorporate the teachings of Honeywell into the teachings of Shah, Osenbach, and Rawlings to include wherein the phase-change material has a thermal conductivity value of about 5 W/mk or greater for the purpose of high thermal performance (Honeywell, page 7). While Honeywell and Chee do not explicitly disclose the Young’s modulus of the phase change material, the instant specification discloses that the TIM may be a commercially available Honeywell PCM (para. [0028]). Since Applicant’s disclosure is enabling for this claim, the Honeywell PCM disclosed in the cited brochure would read on the claim limitations, specifically the Young’s modulus being about 10 MPa or less as claimed in claim 32. Claim 26 is rejected under 35 U.S.C. 103 as being unpatentable over Shah, Osenbach, and Rawlings as applied to claim 21 above, and further in view of Chee et al. (“Chee” US 2022/0344297). Regarding claim 26, the combinations of teachings of Shah, Osenbach, and Rawlings do not disclose the force applied during the attachment of the heat sink (106). Chee discloses, however, wherein the pressing the heat sink (512) towards the package substrate (504) utilizes a first force between about 3 kgf and about 20 kgf (para. [0050] discloses the clamping force is between 0.1-1.5 kgf) and the clamping process is run at a temperature ranging between about 70°C and about 120 °C (para. [[0051]) for a period of time ranging between about 20 min and about 120min (para. [0051]). It would have been obvious to a person having ordinary skill in the art to incorporate the teachings of Chee into the combination of the teachings of Shah, Osenbach, and Rawlings to include the clamping force and curing temperature and duration for the purpose of utilizing a force adequate for securely attaching the heat sink to the package, and utilizing a curing temperature and duration adequate for adhering the lid to the package and solidifying the boundary layer. See KSR International Co. v. Teleflex Inc., 82 USPQ2d 1385 (2007). While the claimed range lies outside of the range disclosed by Chee, a prima facie case of obviousness exists where the claimed ranges or amounts do not overlap with the prior art but are merely close (see MPEP 2144.05(I)). The instant specification is absent criticality for the range of the first force, in fact, para. [0035] of the instant specification reads “[h]owever, any suitable parameters may be utilized” regarding clamping force, curing time, and curing temperature. Further, the claim language “about” used for approximating the first force range is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree. Response to Arguments Applicant's arguments filed October 30 2025 have been fully considered but they are not persuasive. Applicant’s arguments and amendments, see Remarks, filed March 3 2026, with respect to the 112(a) rejections of claims 1, 21, and 27 have been fully considered and are persuasive. The 112(a) rejections of claims 1, 21, and 27 have been withdrawn. Applicant’s arguments with respect to the prior art rejections have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Genevieve G Bullard-Connor whose telephone number is (571)270-0609. The examiner can normally be reached Mon-Fri, 9am-5pm. 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) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Dale Page can be reached at 571-270-7877. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Genevieve G Bullard-Connor/Examiner, Art Unit 2899 /DALE E PAGE/Supervisory Patent Examiner, Art Unit 2899
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Prosecution Timeline

Jun 06, 2022
Application Filed
Jun 30, 2025
Non-Final Rejection mailed — §103
Oct 30, 2025
Response Filed
Dec 03, 2025
Final Rejection mailed — §103
Jan 20, 2026
Response after Non-Final Action
Mar 03, 2026
Request for Continued Examination
Mar 11, 2026
Response after Non-Final Action
May 14, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

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Study what changed to get past this examiner. Based on 3 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
50%
Grant Probability
97%
With Interview (+46.7%)
3y 8m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 14 resolved cases by this examiner. Grant probability derived from career allowance rate.

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