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 .
Applicant’s arguments and amendments filled April 10, 2026 have been entered and considered.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 April 24, 2026 has been entered.
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.
Claims 1 and 4-7 are rejected under 35 U.S.C. 103 as being unpatentable over Cappelletti (US 20200381618 A1), in view of Lee et al. (US 20210328139 A1).
Regarding claim 1, Cappelletti teaches:
A memory device [10, paragraph [0042, Fig. 1] comprising:
a bottom electrode [112, paragraph [0051-0054], Fig. 1] having a top surface;
a memory cell [100, paragraph [0051], Fig. 1; 200, paragraph [0063], Fig. 2A] disposed above the bottom electrode [112, Fig. 1], said memory cell [100, Fig. 1; 200, Fig. 2A] having a bottom layer [106, paragraph [0048], Fig. 1; 206, paragraph [0067], Fig. 2A] comprising a phase change material;
a resistive projection liner element [210, paragraph [0070-0071], Fig. 2A] connecting to the bottom layer of said memory cell [206, Fig. 2A]; and
a heater element [102, paragraph [0051], Fig. 1; 202, paragraph [0065-0066], Fig. 2A] connecting the top surface of said bottom electrode [112, Fig. 1] to said resistive projection liner element [210, Fig. 2A], the resistive projection liner element [210, Fig. 2A] aligned to the metal heater element [102, Fig. 1; 202, Fig. 2A] to reduce an area of contact to said memory cell [100, Fig.1; 200, Fig. 2A].
wherein a width dimension of said resistive projection liner conductor [210, paragraph [0070-0071], Fig. 2B] is substantially equal to a width dimension of said heater element [202, paragraph [0070], Fig. 2B] and the bottom layer [206, paragraph [0067], [0077], Fig. 3B-3C] comprising a phase change material [206A, paragraph [0078], Fig. 3B-3C] of the memory cell [200, paragraph [0063-0065], Fig. 2A] is of a larger width dimension compared to a width dimension of the heater element [202, Fig. 2A].
Cappelletti does not teach:
A bottom metal electrode.
A metal heater element.
The bottom layer comprising a phase change material of the memory cell is of a larger width dimension compared to a width dimension of the metal heater element and self-aligned resistive projection liner conductor.
Lee et al. teaches:
A bottom metal [216, paragraph [0038], Fig. 12] electrode.
A metal [104, paragraph [0011], Fig. 12] heater element.
The bottom layer comprising a phase change material [112, paragraph [0018], [0029], [0034], Fig. 11] of the memory cell [20, paragraph [0034], Fig. 11] is of a larger width dimension compared to a width dimension of the metal heater element [104, paragraph [0011], Fig. 11] and self-aligned resistive projection liner conductor [108, paragraph [0034-0035], Fig. 11].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate the teachings of Lee et al. into the teachings of Cappelletti to include a bottom metal electrode and a metal heater element, the bottom layer comprising a phase change material of the memory cell is of a larger width dimension compared to a width dimension of the metal heater element and self-aligned resistive projection liner conductor, for the purpose of utilizing a good conductor where necessary and resolving an overlay shift or misalignment issue of the storage element layer. Due to a limited number of available materials, using a metal material for a conductor would be obvious to try. (MPEP 2143(I)(E) Examples of Rationales)
The limitation of “the resistive projection liner element being self-aligned to the metal heater element…” is considered product-by-process where patentability is based on the product itself (see MPEP 2113(I) Product-By-Process Claims).
Regarding claim 4, Cappelletti and Lee et al. teach the memory device as claimed in Claim 1.
Cappelletti does not teach:
wherein a length of said resistive projection liner conductor is less than the length of said memory cell bottom layer.
Lee et al. teaches:
wherein a length of said resistive projection liner conductor [108, paragraph [0034], Fig. 11] is less than the length of said memory cell [20, paragraph [0034], Fig. 11] bottom layer [102, paragraph [0034], Fig. 11].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate the teachings of Lee et al. into the teachings of Cappelletti and Lee et al. to include wherein a length of said resistive projection liner conductor is less than the length of said memory cell bottom layer, for the purpose of reducing contact area and improving efficiency.
Regarding claim 5, Cappelletti and Lee et al. teach the memory device as claimed in Claim 1.
Cappelletti further teaches:
a dielectric material heater structure [104, paragraph [0047], Fig. 1; 204, paragraph [0066], Fig. 2A] having a sidewall edge extending in a first orientation and in alignment with a surface of said bottom electrode [112, paragraph [0051], Fig. 1], wherein the metal heater element [102, Fig. 1; 202, Fig. 2A] includes a side wall electrode portion formed on said sidewall edge of the dielectric material heater structure [104, Fig. 1; 204, Fig. 2A] and includes a bottom portion connecting the top surface of the bottom electrode [112, paragraph [0051], Fig. 1].
Cappelletti does not teach:
Bottom metal electrode.
Lee et al. teaches:
Bottom metal [216, paragraph [0038], Fig. 12] electrode.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate the teachings of Lee et al. into the teachings of Cappelletti and Lee et al. to include a bottom metal electrode, for the purpose of utilizing a good conductor where necessary. Due to a limited number of available materials, using a metal material for a conductor would be obvious to try. (MPEP 2143(I)(E) Examples of Rationales)
Regarding claim 6, Cappelletti and Lee et al. teach the memory device as claimed in Claim 1.
Cappelletti does not teach:
wherein the bottom electrode is formed in a dielectric material layer of a semiconductor wafer.
Lee et al. teaches:
wherein the bottom electrode [216, Fig. 12] is formed in a dielectric material layer [215, paragraph [0038], Fig. 12].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate the teachings of Lee et al. into the teachings of Cappelletti and Lee et al. to include wherein the bottom electrode is formed in a dielectric material layer of a semiconductor wafer, for the purpose of facilitating the flow of electrical charge, improving efficiency and performance, and preventing short circuits.
Regarding claim 7, Cappelletti and Lee et al. teach the memory device as claimed in Claim 1.
Cappelletti further teaches:
a plurality of bottom electrodes [112, Fig. 1] each having a top surface, wherein a single memory cell [100, paragraph [0051], Fig. 1] is disposed above and electrically connected to two bottom electrodes [112, Fig. 1] via respective side wall metal heater elements [102, Fig. 1; 202, Fig. 2A].
Cappelletti does not teach:
Bottom metal electrodes.
Lee et al. teaches:
Bottom metal [216, paragraph [0038], Fig. 12] electrodes.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate the teachings of Lee et al. into the teachings of Cappelletti and Lee et al. to include the bottom metal electrodes, for the purpose of utilizing a good conductor where necessary. Due to a limited number of available materials, using a metal material for a conductor would be obvious to try. (MPEP 2143(I)(E) Examples of Rationales)
Response to Arguments
Applicant’s arguments with respect to independent claim 1 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.
Applicant argues on pages 1-5, Section: Rejections Based on 35 U.S.C. §103, in remarks filed April 10, 2026 that the current prior art of record does not teach the amendments to independent claim 1. Examiner agrees with Applicant; However, after a new line of search and consideration of the prior art, the amended limitations of independent claim 1 can be overcome by new considerations of the combination of primary reference Cappelletti (US 20200381618 A1) and secondary reference Lee et al. (US 20210328139 A1).
Applicant argues on page 4, Section: Rejections Based on 35 U.S.C. §103, in remarks filed April 10, 2026 that secondary reference Lee et al. (US 20210328139 A1) does not teach a metal heater element. Examiner disagrees with Applicant. As stated in Office Actions dated August 12, 2025 and February 10, 2026; Lee et al. teaches a metal heater element [104, paragraph [0011]]. Paragraph [0011] of Lee et al. states: “In some embodiments, the bottom electrode 104 includes a conductive material, such as Ti, Co, Cu, AlCu, W, TiN, TiW, TiAl, TiAlN, Ru, RuO.sub.x, or a combination thereof. In some alternative embodiments, the bottom electrode 104 is referred to as a heater that is electrically coupled to the overlying structures (e.g. coupled to a storage element layer formed in subsequent steps). The heater is configured to generate heat in proportion to a current applied across the heater. In the case, the heater may be made of titanium nitride (TiN), titanium carbide (TiC), tungsten nitride (WN), some other high resistance material, Ru, RuO.sub.x, or a combination thereof. In addition, the heater may have a round, square, or rectangular profile in a top view.”
Applicant argues on pages 4-5, Section: Rejections Based on 35 U.S.C. §103, in remarks filed April 10, 2026 that all claims dependent on independent claim 1 should be in condition for allowance. Examiner disagrees with Applicant for at least the reasons mentioned above.
In summary, the amended limitations of independent claim 1 can be overcome by new considerations of the combination of primary reference Cappelletti (US 20200381618 A1) and secondary reference Lee et al. (US 20210328139 A1). Applicant’s argument that element 104 of Lee et al. is not a heater, is not persuasive. All claims directly or indirectly dependent on independent claim 1 are also rejected for at least the reasons mentioned above.
Conclusion
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/D.M.H./Examiner, Art Unit 2815 05/12/2026
/MONICA D HARRISON/Primary Examiner, Art Unit 2815
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