Prosecution Insights
Last updated: May 29, 2026
Application No. 17/965,554

TREATMENT LIQUID, CHEMICAL MECHANICAL POLISHING METHOD, AND METHOD FOR TREATING SEMICONDUCTOR SUBSTRATE

Final Rejection §103
Filed
Oct 13, 2022
Priority
Apr 16, 2020 — JP 2020-073261 +2 more
Examiner
ALANKO, ANITA KAREN
Art Unit
1713
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Fujifilm Corporation
OA Round
4 (Final)
70%
Grant Probability
Favorable
5-6
OA Rounds
0m
Est. Remaining
52%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allowance Rate
477 granted / 685 resolved
+4.6% vs TC avg
Minimal -18% lift
Without
With
+-17.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
32 currently pending
Career history
718
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
67.7%
+27.7% vs TC avg
§102
9.9%
-30.1% vs TC avg
§112
10.1%
-29.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 685 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 . Election/Restrictions Applicant’s election without traverse of Invention I (treatment liquid), Species A (ammonium) and Species a (heteroaromatic compound) in the reply filed on November 7, 2024, is acknowledged. 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 text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1, 8-9, 12, 15, 17-18 and 21-28 are rejected under 35 U.S.C. 103 as being unpatentable over Yamada et al (JP 2010-129871 A) in view of Yamada (US 2009/0311864 A1). Yamada ’871 discloses a treatment liquid for a semiconductor substrate (abstract), comprising: a component A having two or more onium structures in a molecule (general formula 2, [0008]-[0009], page 6, line 26-page 7, line 1 of English translation; [0030]-[0033], page 12, line 21-page 13, line 2); water ([0013], page 8, lines 30-31); and a heteroaromatic compound ([0049], page 17, lines 18-22), wherein the treatment liquid has a pH of 14 or less ([0067], page 21, lines 40-41), or pH of 2-11, which encompass or overlap with the cited range of 8.0 to 13.5, and the component A is a compound represented by General Formula (I), PNG media_image1.png 251 661 media_image1.png Greyscale (general formula 2), where in General Formula (I), R1 to R6 each independently represents a monovalent organic group (page 3, lines 11-12), two of R1 to R6 may be bonded to each other (page 3, lines 15-16), L1 represents a divalent linking group which is an aromatic hydrocarbon group (M as an arylene group, page 3, line 13), or a group formed by a combination of an aliphatic hydrocarbon group and an aromatic hydrocarbon group (“alkylene group, …, arylene group, or a group combining two or more of these groups”, page 3, lines 12-14), n represents 1 or 2 and X(2/n)- represents a (2/n)- valent counterion (“X- represents a monovalent anion, and Y2- represents a divalent anion” page 3, lines 14-15). Yamada ’871 fails to explicitly disclose the pH at a temperature of 25 °C as cited. However, the composition is substantially similar to the instant invention. Yamada ’871 fails to disclose significant changes in temperature, and measurements are expected to occur at room temperature, which is about 25 °C. Accordingly, the pH is expected to fall in the cited range at the cited temperature. As to amended claim 1, Yamada ’871 discloses that the content of the component A is 0.001 g/L or more from the view point of improving the polishing ability, and 10 g/L or less from the viewpoint of sufficient slurry stability. ([0047], page 17, lines 8-10). In one example, Yamada ’871 discloses component A is present at 2.0 g/L (Example 1, composition 1, page 26, line 37) with water added to make a 1000 mL solution (page 26, line 38), which is 0.2% by mass. Accordingly, Yamada ’871 discloses 0.0001-1% by mass of compound A, which overlaps with the cited range of 0.8% or more. Yamada ’864 teaches that component A may be present at amounts greater than 1% by mass, and thus renders obvious increased amounts of component A. Yamada ’871 and Yamada ’864 both use component A as a treatment liquid for a semiconductor substrate (see abstracts). Yamada ’864 teaches the same component A as Yamada ’871 (e.g., see A23 reproduced below). PNG media_image2.png 113 177 media_image2.png Greyscale PNG media_image3.png 114 410 media_image3.png Greyscale Compound A (Yamada ’871, page 15; Yamada ’864, [0105], page 8). Yamada ’864 teaches that component A may be present in an amount of 0.0001 wt% - 5 wt% [0108], which is about up to 5 % by mass. Yamada teaches that lower amounts optimize the polishing rate, while higher amounts optimize slurry stability [0108]. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include 0.8% or more of compound A in the treatment liquid of Yamada ’871 because Yamada ’864 teaches to optimize the concentration from the viewpoints of polishing rate and slurry stability. MPEP 2144.05, II, A. Further as to amended claim 1, Yamada ’871 fails to disclose the composition of the anion, X-. Yamada ’864 teaches that the anion in component A may comprise hydroxide ion [0104]. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include a hydroxide ion in component A in the treatment liquid of Yamada ’871 because Yamada ’864 teaches that it is useful to include when a treatment liquid includes component A. As to claim 8, see the rejection of claim 1. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include 0.8% to 5 % by mass of component A in the treatment liquid of Yamada ’871 because Yamada ’864 teaches to optimize the concentration from the viewpoints of polishing rate and slurry stability. MPEP 2144.05, II, A. As to claim 9, Yamada ’871 discloses to include an organic acid ([0062], page 20, lines 35-39). As to claim 12, Yamada ’871 discloses that the heteroaromatic compound is a tetrazole compound (page 20, line 3), a triazole (page 20, lines 6-10), imidazole (page 19, line 38), or a pyrazole compound (page 17, line 38). As to claim 15, Yamada ’871 discloses to include a surfactant ([0017], page 9, lines 27-34). As to claims 17-18, Yamada ’871 discloses to include colloidal silica having an average primary particle diameter of 5-200 nm (page 9, lines 6-7), which overlaps with the cited range. As to claim 21, see the rejection of claim 1. Yamada ’871 discloses that the treatment liquid is a concentrated liquid that can be diluted at point of use ([0079], page 24, lines 7-8). Accordingly, the mass percentage can be much higher that taught by Yamada ’871 prior to dilution. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include 0.8% to 5 % by mass, which overlaps with the cited range, and even up to 20 mass% of component A in the treatment liquid of Yamada ’871 because Yamada ’864 teaches to optimize the concentration from the viewpoints of polishing rate and slurry stability, and increasing up to 20 mass% is expected to be useful for later dilution. MPEP 2144.05, II, A. As to claim 22, Yamada ’871 discloses that the heteroaromatic compound is, in one example, present at 2.0 g/L (page 26, line 33), which for a 1000 mL treatment liquid (page 26, line 38) is about 0.2% by mass, which is within the cited range. A specific example in the prior art that is within a claimed range anticipates the range. MPEP 2131.03. As to claim 23, Yamada ’871 discloses that the treatment liquid may further comprise an amino alcohol (e.g. diethanolamine, page 22, lines 5-6). As to claim 24, Yamada ’871 discloses to add the amino alcohol at 0.0001 to 2.0 mol (page 22, line 12), which for a 1000 mL solution (page 26, line 38), is 0.0001 mol/L at its lower limit, for diethanolamine, is about 0.01% by mass, which is within the cited range. As to claim 25, Yamada ’871 discloses a dilution ratio of 1 to 20 times by volume (page 8, line 31), which is within the cited range. A specific example in the prior art that is within a claimed range anticipates the range. MPEP 2131.03. As to claims 26-27, Yamada ’871 discloses a phenylene group ([0039], page 14, line 24, A23 on page 15) and a biphenyl group (A32 on page 16, [0043]). As to claim 28, see the rejection of claim 1. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include 3 % by mass or more of component A in the treatment liquid of Yamada ’871 because Yamada ’864 teaches varying the composition in order to optimize the treatment liquid from the viewpoints of polishing rate and slurry stability. MPEP 2144.05, II, A. Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Yamada et al (JP 2010-129871 A) in view of Yamada (US 2009/0311864 A1), as applied to claim 1, and further in view of Kikkawa et al (US 2022/0073820 A1). As to claim 14, Yamada ’871 fails to disclose to include an organic solvent. Kikkawa teaches a treatment liquid for a semiconductor substrate (see abstract, e.g., CMP [0244]) similar to Yamada ’871 comprising a component A [0248]. Kikkawa teaches that the treatment liquid may include an organic solvent [0261], [0266]. It would have been obvious to one with ordinary skill in the art before the effective filing date of the claimed invention to include an organic solvent in the treatment liquid of Yamada ’871 because Kikkawa teaches that it is useful and such is expected to give the predictable result of a treatment liquid suitable for treating semiconductor substrates. Response to Amendment Applicant’s arguments, see pages 7-8, filed October 8, 2025, have been considered. The following rejections are withdrawn: the 35 USC 102 rejection over Yamada ‘871, and the 35 USC 103 rejection over Yamada ’871 in view of Mizutani. The 35 USC 102 is withdrawn in view of the claim amendment to the mass percentage of component A in the treatment liquid. Yamada ’871 provides an example of the content of component A which is outside the newly cited range. Reliance upon Mizutani is withdrawn because newly applied Yamada ’864 already teaches a hydroxide ion. Claims 1, 8-9, 12, 15, 17-18 and 21-28 are newly rejected under 35 U.S.C. 103 as being unpatentable over Yamada et al (JP 2010-129871 A) in view of Yamada (US 2009/0311864 A1). Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Yamada et al (JP 2010-129871 A) in view of Yamada (US 2009/0311864 A1), as applied to claim 1, and further in view of Kikkawa et al (US 2022/0073820 A1). The rejection in view of Kikkawa is amended to reflect newly applied Yamada (US 2009/0311864 A1) applied to claim 1. Response to Arguments Applicant's arguments filed October 8, 2025, have been fully considered but they are not persuasive, to the extent they still apply. Applicant argues that exemplary compound in Example 1 is different from the component A in claim 1. In response, Example 1 is used to disclose an example from which to extrapolate the mass percentage of component A. However, upon further review, Yamada ’871 discloses the mass percentage in another passage [0047], which generalizes to all components A, even, e.g., component A23 (reproduced above in the rejection), which reads on claim 1. Therefore, example 1 is not relied upon to reject the claims. The rejection does not rely on component A1, but on many compounds, including e.g., A23. Applicant argues that the working examples and paragraph [0262] and [0276] show that the corrosion prevention performance is more excellent. In response, the working examples have been reviewed but it is not clear that unexpected results occur in the cited ranges. The examples have “A” or “B” corrosion prevention performance, but this is not unexpected because changes in composition are expected to change the results. Furthermore, a composition/treatment liquid in the prior art can be used for different purposes than described by applicant, and still be a proper rejection so long as the same composition/treatment liquid is described. Yamada et al (JP 2010-129871 A) in view of Yamada (US 2009/0311864 A1) fairly teach the claimed invention, as described above in the rejection. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANITA K ALANKO whose telephone number is (571)270-0297. The examiner can normally be reached Monday-Friday, 9 am-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, Joshua Allen can be reached on 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 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. /ANITA K ALANKO/Patent Examiner, Art Unit 1713
Read full office action

Prosecution Timeline

Show 1 earlier event
Dec 13, 2024
Non-Final Rejection mailed — §103
Mar 13, 2025
Response Filed
Mar 21, 2025
Final Rejection mailed — §103
Jun 23, 2025
Request for Continued Examination
Jun 27, 2025
Response after Non-Final Action
Jul 09, 2025
Non-Final Rejection mailed — §103
Oct 08, 2025
Response Filed
Dec 23, 2025
Final Rejection mailed — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
70%
Grant Probability
52%
With Interview (-17.7%)
3y 0m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 685 resolved cases by this examiner. Grant probability derived from career allowance rate.

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