DETAILED ACTION
This Office Action is in response to the Request for Continued Examination filed 27 April 2026. Claims 1-4, 6-15 are pending in this application. Claims 4, 7-15 have been withdrawn from consideration.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 27 April 2026 has been entered.
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) 1-2, 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Do et. al (US 2016/0079524 A1) (newly cited) in view of Manfrini et. al (US 2021/0098530 A1) (of record) and Schravendijk et. al (US 2020/0152452 A1) (of record)
Regarding Claim 1, Do discloses (as shown in Fig. D) A semiconductor device ([0047] FIGS. 3A to 3D are cross-sectional views illustrating a method for fabricating a semiconductor device) ([0083] The memory unit 1010 may include one or more of the above-described semiconductor devices in accordance with the implementations) comprising:
a memory cell ([0048] Referring to FIG. 3A, a predefined structure, e.g., a substrate 11 where a switching element (not shown) is formed is provided. Herein, the switching element is for selecting a predetermined unit cell in the semiconductor device including a plurality of unit cells) disposed over a substrate ([0049] first inter-layer dielectric layer 12) and including a variable resistance layer ([0051] Subsequently, variable resistance elements M);
a protection layer ([0072] For example, the first aluminum nitride layer 17 may be or include a stacked structure of the aluminum nitride layer 17A containing carbon and oxygen) disposed on side surfaces of the memory cell (M) and an upper surface of the substrate (12) on which the memory cell (M) is not disposed; ([0072] A surface of the first aluminum nitride layer 17 coupled with the variable resistance elements M may be converted to an aluminum nitride layer 17A containing carbon and oxygen through the thermal process.) (See Fig. 3D, showing the aluminum nitride layer 17A containing carbon and oxygen on the sidewalls of the variable resistance elements M and on the top surface of the dielectric layer 12)
a first encapsulation layer ([0072] aluminum nitride layer 17 containing carbon) disposed on the memory cell (M) and the protection layer (17A), (See Fig. 3D, showing the aluminum nitride layer 17 on the aluminum nitride layer 17A containing carbon and oxygen which is on the variable resistance elements M)
an additional protection layer ([0073] the second aluminum nitride layer (AlN) 18) disposed on the first encapsulation layer (17); (See Fig. 3D, showing the aluminum nitride layer 18 on the aluminum nitride layer 17)
and a second encapsulation layer ([0074] second inter-layer dielectric layer 19) disposed on the additional protection layer (18), ([0074] Referring to FIG. 3D, a second inter-layer dielectric layer 19 may be formed over the second aluminum nitride layer 18)
However, Do fails to disclose a selector layer;
wherein the protection layer (17A) includes a treated surface that is modified by a material including helium.
wherein the additional protection layer (18) includes a treated surface that is modified by a material including helium.
Manfrini discloses (as shown in Fig. 23) a selector layer ([0072] tunnel junction selector 150);
and the protection layer ([0072] dielectric capping layer 220) is disposed on an upper surface of the substrate ([0067] substrate 100) on which the memory cell ([0061] MRAM cell 20 and MRAM cell 25) is not disposed (See Fig. 23, showing the conformally deposited capping layer 220 extending on the surface above substrate 100 where there is no memory cell 20, 25)
It would have been obvious before the effective filing date of the application to combine the teachings of Do and Manfrini. Manfrini teaches that the selector layer (150) is placed in series with the MTJ tunnel structure (130) in a single pillar in order to save space and the increase density of memory cells. ([0062] Because the tunnel junction selector 150 is placed in series with the MTJ structure 130 in a single pillar, cell size of the MRAM cells may be decreased. As a result, the spacing between MRAM cells may also be decreased and the density of the MRAM device may increase.) It would have been obvious to place the selector layer placed in series with the MTJ tunnel structure (130) in a single pillar in order to save space and the increase density of MRAM memory cells in Do ([0096] The nonvolatile memory may include … a magnetic random access memory (MRAM), a memory with similar functions.).
However, Manfrini fails to disclose wherein the protection layer (220) includes a treated surface that is modified by a material including helium, and
wherein the additional protection layer includes a treated surface that is modified by a material including helium.
Schravendijk discloses (as shown in Fig. 2A) wherein the protection layer ([0040] conformal encapsulation layer 109) includes a treated surface that is modified by a material including helium. ([0004] In various embodiments, the method further includes exposing the encapsulation layer to a post-treatment process at a temperature less than 300° C… [0005] For example, in some embodiments, the post-treatment process includes exposing the substrate to a post-treatment gas and igniting a second plasma without a reactant... In some embodiments, the post-treatment gas is any one of nitrogen, ammonia, helium, argon, and combinations thereof.) ([0087] It is believed that periodic exposure to longer durations of plasma with inert gas reduces hydrogen content of the deposited encapsulation layer. The upper region of the encapsulation layer may have reduced hydrogen content. For example, in some embodiments, the top about 25 Å to about 30 Å of the encapsulation layer may have reduced hydrogen content.)
It would have been obvious to one having ordinary skill in the art before the effective filing date to combine the teachings of Do in view of Manfrini and Schravendijk. Schravendijk teaches that the post-treatment in helium reduces hydrogen content in the encapsulation layer, improving the quality of the encapsulation layer. Manfrini teaches that the capping layer may be formed by a PECVD process. ([0056] In accordance with some embodiments, dielectric capping layer 220 is formed of silicon nitride, silicon oxynitride, or the like. The formation process may be a CVD process, an ALD process, a Plasma Enhance CVD (PECVD) process, or the like) Schravendijk teaches that the post-treatment process may be performed on an encapsulation layer performed by a convention PECVD process. ([0083] In some embodiments, post-treatment methods described herein may be used with conventional PECVD of encapsulation layers to reduce hydrogen content and improve the quality of the deposited layers) It would have been obvious to perform the post-treatment in Schravendijk on the capping layer 220 in Manfrini in order to reduce hydrogen content and increase the quality of the film.
However, Schravendijk fails to disclose wherein the additional protection layer includes a treated surface that is modified by a material including helium.
It would have been obvious to one having ordinary skill in the art before the effective filing date to combine the teachings of Do in view of Manfrini and Schravendijk in order treat the surface with a material including Helium. Schravendijk teaches that the post-treatment in helium reduces hydrogen content in the encapsulation layer, improving the quality of the encapsulation layer. It would have been obvious to also perform the post-treatment in Schravendijk on the second capping layer 128 in Do in order to also reduce hydrogen content and increase the quality of the additional protective film.
Regarding Claim 2, Manfrini further discloses (as shown in Fig. 23) wherein the protection layer (220) is structured to prevent energy transfer to the selector layer (150). ([0056] dielectric capping layer 220 is formed of silicon nitride, silicon oxynitride, or the like)
Schravendijk further discloses (as shown in Fig. 2A) wherein the protection layer (109) is structured to prevent material diffusion to the variable resistance layer. ([0040] A conventional encapsulation layer 109 may include hydrogen 115, which may diffuse into the magnetic tunnel junction… [0083] post-treatment methods described herein may be used with conventional PECVD of encapsulation layers to reduce hydrogen content)
Claim Interpretation Note: The limitation “to prevent material diffusion to the variable resistance layer and prevent energy transfer to the selector layer” is functional language. MPEP 2114(ii) instructs "[A]pparatus claims cover what a device is, not what a device does." Hewlett-Packard Co. v. Bausch & Lomb Inc., 909 F.2d 1464, 1469, 15 USPQ2d 1525, 1528 (Fed. Cir. 1990) (emphasis in original), and that a claim containing a "recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus" if the prior art apparatus teaches all the structural limitations of the claim. Ex parte Masham, 2 USPQ2d 1647 (Bd. Pat. App. & Inter. 1987)
Regarding Claim 6, Do further discloses (as shown in Fig. 3D) wherein one of the first encapsulation layer (17) and the second encapsulation layer (19) includes an oxide ([0074] The second inter-layer dielectric layer 19 may include a single layer including an oxide layer, a nitride layer or an oxide-nitride layer or a stacked layer where two or more of them are stacked.)
and the other of the first encapsulation layer (17) and the second encapsulation layer (19) includes an oxide or includes a nitride. ([0072] the aluminum nitride layer 17 containing carbon)
Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Do in view of Manfrini and Schravendijk as applied to claim 1 above, and further in view of Igarashi et. al (US 2023/0083008 A1) and Lai et. al (US 2020/0127046 A1).
Regarding Claim 3, Manfrini further discloses (as shown in Fig, 23) wherein the variable resistance layer includes a magnetic tunnel junction (MTJ) structure ([0029] magnetic tunnel junction (MTJ) structure 130…[0036] This property allows the magnetic spin of the free layer 138 of the MTJ structure 130 to be put into parallel or anti-parallel mode with the reference layer 134, and thereby control the resistance associated with the MRAM cell)
However, Manfrini fails to disclose the selector layer includes a dielectric material and a dopant.
Igarashi discloses (as shown in Fig. 6) the selector layer includes a dielectric material and a dopant. ([0045] Note that the two-terminal type switching element 2 as the selector 2 may include, for example, an insulator including a dopant (an impurity))
It would have been obvious before the effective filing date of the application to combine the teachings of Do and Manfrini to make the variable resistance memory structure of Do be a MTJ structure. Do teaches that the nonvolatile memory can be an MRAM, which is a type of MTJ. ([0096] The nonvolatile memory may include … a magnetic random access memory (MRAM), a memory with similar functions.) Therefore, it would have been obvious for the nonvolatile memory structure in Do, which is the variable resistance memory, to be an MTJ as in Manfrini.
It would have been obvious before the effective filing date of the application to combine the teachings of Do in view of Manfrini and Schravendijk with Igarashi in light of the teachings of Lai. Lai teaches that when the selector is made from a doped insulator, the threshold voltage can be controlled by changing the dopant concentration. ([0042] In some embodiments, doping concentrations of the insulators 404 are varied to adjust threshold voltages of the first and second unipolar selectors 108, 110. For example, increasing a doping concentration of an insulator may decrease a threshold voltage of the corresponding selector whereas decreasing the doping concentration may increase the threshold voltage.) It would have been obvious to replace the metal selector (150) with the doped insulator selector (2) of Igarashi in order to control the threshold voltage of the selector.
Response to Arguments
Applicant's arguments filed 27 April 2026 have been fully considered but they are not persuasive.
Applicant argues (on page 10, first paragraph) in their remarks filed 27 April 2026 that “Schravendijk discloses a post-treatment process applied to an encapsulation layer, and does not disclose the resulting structure as including a “treated surface modified by a material including helium” as required by Claim 1.” This argument is found unpersuasive. Schravendijk teaches that performing a post-treatment plasma exposure to plasma with inert gases reduces hydrogen content of the encapsulation region. ([0087] It is believed that periodic exposure to longer durations of plasma with inert gas reduces hydrogen content of the deposited encapsulation layer.) Furthermore, Schravendijk teaches that it is the upper portion of the encapsulation layer that has reduced hydrogen content. ([0087] The upper region of the encapsulation layer may have reduced hydrogen content. For example, in some embodiments, the top about 25 Å to about 30 Å of the encapsulation layer may have reduced hydrogen content.) Therefore, the upper surface is modified by the process in Schravendijk; specifically, the upper surface is modified by as having a reduced hydrogen content. Schravendijk further reveals that the post-treatment gas used may include helium. ([0087] The post-treatment gas may include nitrogen only, ammonia only, nitrogen/ammonia mixture, argon only, helium only, argon/helium mixture, and combinations thereof.)
Applicant further argues that this interpretation of “modification of the surface” is overly broad. (Remarks, Page 10-11) While Applicant uses the material including helium to modify the surface roughness of the protection film, the claim does not claim how the surface is modified, only that that the treated surface is modified by the material containing helium. This is a broad limitation, as any modification to the surface by the helium containing material is covered by the claim. One such modification would be reduction in the hydrogen content at the surface of the protection layer.
Therefore, the modification illustrated in Schravendijk, reducing the hydrogen content in the upper portion of the encapsulation layer ([0087] It is believed that periodic exposure to longer durations of plasma with inert gas reduces hydrogen content of the deposited encapsulation layer.) is a modification to the surface by the inert gas plasma. The surface exposed to the inert plasma has a lower hydrogen content after the post treatment, this is a modification. Schravendijk further teaches that there are other modifications that occur during this post treatment. Schravendijk teaches that the encapsulation layer becomes denser following the post treatment. ([0087] thereby generating a plasma species that may be capable of modifying and densifying the deposited encapsulation layer.) This is another way the treated surface is modified by the post treatment process in Schravendijk. Furthermore, it would be obvious to use an inert gas involving helium since Schravendijk specifically discloses helium and argon/helium as post treatment gases ([0087]).
Applicant further argues (in the Remarks on page 11, second paragraph) that the Schravendijk only discloses treating a single encapsulation layer, therefore it does not teach two distinct protection layers (the protection layer and additional protection layer) that are modified by a material containing Helium. Examiner agrees that Schravendijk on its own does not teach this limitation. However, the combination of references makes this obvious. Firstly, Do teaches two distinct aluminum nitride layers grown by ALD deposition. In the rejection of claim 1, these aluminum nitride layers are the claimed protection layer and additional protection layers. Furthermore, aluminum nitride films grown by ALD processes are known to contain hydrogen as contaminant ([Abstract lines 5-8] Hydrogen is known to be a frequent contaminant in AlN films grown by ALD method, it may form different bonds with nitrogen, e.g. amino (–NH2) or imide (–NH) groups, which impair the quality of the resulting film. (Dallaev et. al; “Investigation of structure of AlN thin films using Fourier-transform Infrared Spectroscopy”, Procedia Structural Integrity, Volume 23, 2019, Pages 601-606) (newly cited)) Therefore, it would have been obvious to use the method of hydrogen removal in Schravendijk on each AlN film grown by ALD in order to remove the hydrogen contaminants in each of the AlN films. Therefore, it would have been obvious to have the surfaces of both protection films (AlN films in Do) treated by the post treatment process in Schravendijk in order to reduce hydrogen contaminants in both AlN films.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JASON JAMES GREAVING whose telephone number is (703)756-5653. The examiner can normally be reached 7:30am - 5:00 pm.
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/JASON JAMES GREAVING/ Examiner, Art Unit 2893
/Britt Hanley/ Supervisory Patent Examiner, Art Unit 2893
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