Prosecution Insights
Last updated: April 19, 2026
Application No. 17/859,013

MEMORY CELL, INTEGRATED CIRCUIT, AND MANUFACTURING METHOD OF MEMORY CELL

Non-Final OA §102§103
Filed
Jul 07, 2022
Examiner
CULBERT, CHRISTOPHER A
Art Unit
2815
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Taiwan Semiconductor Manufacturing Company Ltd.
OA Round
3 (Non-Final)
41%
Grant Probability
Moderate
3-4
OA Rounds
3y 8m
To Grant
46%
With Interview

Examiner Intelligence

Grants 41% of resolved cases
41%
Career Allow Rate
137 granted / 333 resolved
-26.9% vs TC avg
Minimal +4% lift
Without
With
+4.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
81 currently pending
Career history
414
Total Applications
across all art units

Statute-Specific Performance

§103
55.8%
+15.8% vs TC avg
§102
20.9%
-19.1% vs TC avg
§112
22.1%
-17.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 333 resolved cases

Office Action

§102 §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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 1/15/2026 has been entered. Claim Rejections - 35 USC § 102 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 (i.e., changing from AIA to pre-AIA ) 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. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 1-6 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Ok et al. (US 2023/0105007 A1). Regarding claim 1, Ok discloses a memory cell (Fig. 10), comprising: a bottom electrode (combination of 203, 211, and 215 in Fig. 3), comprising a first electrode (203) and a second electrode (215) spatially separated from the first electrode; a thermal preservation layer (213; 213 is understood as being a thermal preservation layer as it is composed of the same material as Applicant’s thermal preservation layer) only partially sandwiched between the first electrode and the second electrode; wherein the thermal preservation layer is in physical contact with the first electrode and the second electrode (see Fig. 10); a first dielectric layer (combination of 201 and 205) laterally surrounding the bottom electrode and the thermal preservation layer; a variable resistance layer (225 in Fig. 9) disposed on the second electrode, the thermal preservation layer, and the first dielectric layer; and a top electrode (233) disposed on the variable resistance layer. Regarding claim 2, Ok further discloses wherein the first electrode is in physical contact with the first dielectric layer (see Fig. 9). Regarding claim 3, Ok further discloses wherein the thermal preservation layer is partially sandwiched between the second electrode and the first dielectric layer (see Fig. 9). Regarding claim 4, Ok further discloses wherein a width of the first electrode is larger than a width of the second electrode (see Fig. 9). Regarding claim 5, Ok further discloses wherein the first electrode and the second electrode are made of a same material (¶ 0027). Regarding claim 6, Ok further discloses wherein the bottom electrode and the thermal preservation layer are made of different materials (¶ 0027). Claim Rejections - 35 USC § 103 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 (i.e., changing from AIA to pre-AIA ) 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. 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) 7-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ok et al. (US 2023/0105007 A1) as applied to claim 1, above, and further in view of Hsu et al. (US 2016/0225986 A1). Regarding claim 7, Ok further discloses a hard mask layer (235 in Fig. 9) disposed on the top electrode; a pair of spacers (255’ in Fig. 9) disposed aside the variable resistance layer, the top electrode, and the hard mask layer; a second dielectric layer (263 in Fig. 10); and a conductive contact (259) penetrating through the second dielectric layer and the hard mask layer to be in physical contact with the top electrode (see Fig. 10). Ok does not disclose an etch stop layer as claimed. Hsu, in the same field of endeavor, discloses forming an etch stop layer over a hard mask (¶ 0035). There was a benefit to forming an etch stop layer as such in that it provides added protection to the underlying components during later processing steps. It would have been obvious to one having ordinary skill in the art before the Application's effective filing date to form an etch stop layer as taught by Hsu over the hard mask of Ok for this benefit. In the resulting configuration, the etch stop layer covers the first dielectric layer, the pair of spacers, and the hard mask layer; the second dielectric layer is disposed on the etch stop layer; and the conductive contact will penetrate the etch stop layer. Regarding claim 8, Ok does not disclose wherein a bottom surface of the conductive contact is located at a level height lower than that of a topmost surface of the top electrode. Hsu discloses forming a top contact (1200 in Fig. 2Q) such that a bottom surface of the conductive contact is located at a level height lower than that of a topmost surface of a top electrode (600). There was a benefit to such a configuration in that it increases the contact area between the conductive contact and the top electrode which increases the electric conductivity. It would have been obvious to one having ordinary skill in the art before the Application's effective filing date to form the conductive contact of Ok such that a bottom surface of the conductive contact is located at a level height lower than that of a topmost surface of a top electrode for this benefit. Regarding claim 9, Ok further discloses that the sidewalls of the hard mask layer, sidewalls of the top electrode, and sidewalls of the variable resistance layer (see Fig. 9). Response to Arguments Applicant's arguments filed 1/15/2026 have been fully considered but they are not persuasive. Applicant argues that the thermal preservation layer of Ok is not in physical contact with both the first electrode and the second electrode. This argument is not persuasive as claim 1 does not require direct contact and physical contact allows for intervening components. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER A CULBERT whose telephone number is (571)272-4893. The examiner can normally be reached M-F 9-5. 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, Joshua Benitez can be reached at (571) 270-1435. 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. /CHRISTOPHER A CULBERT/ Examiner, Art Unit 2815
Read full office action

Prosecution Timeline

Jul 07, 2022
Application Filed
Apr 18, 2025
Non-Final Rejection — §102, §103
Jun 04, 2025
Interview Requested
Jul 11, 2025
Applicant Interview (Telephonic)
Jul 11, 2025
Examiner Interview Summary
Aug 04, 2025
Response Filed
Nov 01, 2025
Final Rejection — §102, §103
Dec 07, 2025
Interview Requested
Jan 15, 2026
Request for Continued Examination
Feb 05, 2026
Response after Non-Final Action
Mar 07, 2026
Non-Final Rejection — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12557465
PHOTOELECTRIC DEVICE
2y 5m to grant Granted Feb 17, 2026
Patent 12532521
METHOD FOR MANUFACTURING SELF-ALIGNED EXCHANGE GATES AND ASSOCIATED SEMICONDUCTING DEVICE
2y 5m to grant Granted Jan 20, 2026
Patent 12520723
ORGANIC LIGHT EMITTING DIODE AND ORGANIC LIGHT EMITTING DEVICE INCLUDING THE SAME
2y 5m to grant Granted Jan 06, 2026
Patent 12512315
METHOD OF MANUFACTURING SEMICONDUCTOR DEVICE
2y 5m to grant Granted Dec 30, 2025
Patent 12501743
MICRO-LED STRUCTURE AND MICRO-LED CHIP INCLUDING SAME
2y 5m to grant Granted Dec 16, 2025
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
41%
Grant Probability
46%
With Interview (+4.4%)
3y 8m
Median Time to Grant
High
PTA Risk
Based on 333 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month