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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 January 30, 2026 has been entered with the RCE filed on February 26, 2026.
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, 6, 10-14, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Rengarajan et al (US Publication 20190221449) in view of Shafiyan-Rad et al (US Publication 20230360990).
Regarding claim 1, Rengarajan teaches a semiconductor package comprising:
a heat radiation substrate (Fig. 5, 112, para 16, "copper; a copper alloy; aluminium; an aluminium alloy; any other metal");
an insulating layer disposed on the heat radiation substrate (Fig. 5, 11, para 16), wherein the insulating layer is in direct contact with the heat radiation substrate (Fig. 5, 11 in direct contact with 112);
a metal pattern layer disposed on the insulating laver (Fig. 5, 111);
a housing disposed on the insulating layer (Fig. 5, 7 disposed on 11), wherein the housing is in direct contact with the insulating layer (Fig. 5, 7 in direct contact with 11),
a semiconductor chip installed on the metal pattern layer (Fig. 5, 20);
a connecting member for electrical connection between the metal pattern layer and the semiconductors chip (Fig. 7, 3, para 25);
one or more terminals formed uprightly on the metal pattern layer (Fig. 5, terminals 4 formed on 111); and
a molding sealing member molded to cover the semiconductor chip, the connecting member, and at least a part of the terminals (Fig. 5, 800 and 801, para 30),
the terminals are formed to be higher than an upper end surface of the housing so that upper ends of the terminals are exposed to an upper part of the molding sealing member and are electrically bonded to external electrical connecting members (Fig. 5, terminals 4 formed to be higher than 7 and 800/801).
Rengarajan does not specifically teach:
wherein the housing is formed of a metal material for additional heat dissipation;
wherein a thickness of the housing is greater than a thickness of the metal pattern layer.
Shafiyan-Rad teaches wherein the housing is formed of a metal material for additional heat dissipation (Fig. 1, 9, para 21);
It would have been obvious to one of ordinary skill in the art before the effective filing date of the present application for Rengarajan to include a metal housing as taught by Shafiyan-Rad in order to improve the structural stability and heat dissipation capacity of the device.
Rengarajan as modified still lacks wherein a thickness of the housing is greater than a thickness of the metal pattern layer.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the present application for Rengarajan to include a housing thicker than the metal pattern layer. A metal housing with a higher thickness provides better structural support and reduces axial thermal stress. A thin metal pattern layer on either side of the insulating layer reduces warpage and axial stress within the metal-insulator-metal substrate.
Regarding claim 6, Rengarajan as modified teaches the limitations of claim 1 upon which claim 6 depends.
Rengarajan teaches wherein the insulating layer comprises one or more metal layers (Fig. 5, 111 and 112).
Regarding claim 10, Rengarajan as modified teaches the limitations of claim 1 upon which claim 10 depends.
Rengarajan teaches wherein the insulating layer is disposed on the heat radiation substrate in a paste or film form and is hardened on the heat radiation substrate through a hardening process (para 15-16).
Furthermore, the present claim is drawn to a device, thus the method of hardening the insulating layer does not patentably distinguish the claimed invention from that of the modified invention of Sato.
It should be noted that a "product by process claim" is directed to the product per se, no matter how actually made, In re Hirao, 190 USPQ 15 at 17 (footnote 3). See also In re Brown, 173 USPQ 685; In re Luck, 177 USPQ 523; In re Fessmann, 180 USPQ 324; In re Avery, 186 USPQ 161; In re Wertheim, 191 USPQ 90 (209 USPQ 554 does not deal with this issue); and In re Marosi et al., 218 USPQ 289, all of which make it clear that it is the patentability of the final product per se which must be determined in a "product by process" claim, and not the patentability of the process, and that an old or obvious product produced by a new method is not patentable as a product, whether claimed in " product by process" claims or not. Note that applicant has the burden of proof in such cases, as the above caselaw makes clear. See also MPEP 2113 [R-1].
Regarding claim 11, Rengarajan as modified teaches the limitations of claim 1 upon which claim 11 depends.
Rengarajan teaches wherein the connecting member is formed of a material containing 50% or more of any one of Au, AI, and Cu (para 21, "copper, aluminum, gold, or silver, for example").
Regarding claim 12, Rengarajan as modified teaches the limitations of claim 1 upon which claim 12 depends.
Rengarajan teaches wherein the molding sealing member is a composite material containing an epoxy component or an insulator containing a Si component (para 30).
Regarding claim 13, Rengarajan as modified teaches the limitations of claim 1 upon which claim 13 depends.
Rengarajan teaches wherein the upper ends of the terminals are formed as a female screw and the external electrical connecting members are formed as a male screw which are bolt-joined to the upper ends of the terminals so that the terminals and the external electrical connecting members are electrically connected to each other (para 20).
Regarding claim 14, Rengarajan as modified teaches the limitations of claim 1 upon which claim 13 depends.
Rengarajan teaches wherein the ends of the terminals are formed to join a press fit pin terminal and are electrically connected to the external electrical connecting members (para 20).
Regarding claim 16, Rengarajan as modified teaches the limitations of claim 1 upon which claim 16 depends.
Rengarajan teaches wherein the heat radiation substrate comprises a cover covering more than 50% of a total area of the molding sealing member (para 35, cover).
Claims 3-5, 7, 8, 15, and 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Rengarajan et al (US Publication 20190221449) in view of Shafiyan-Rad et al (US Publication 20230360990) and further in view of Sato (US Publication US20220230891).
Regarding claims 3-5, Rengarajan as modified teaches the limitations of claim 1 upon which claims 3-4 depend.
Rengarajan does not specifically teach:
[claim 3] wherein the heat radiation substrate comprises a metal material and radiation fins are arranged on the bottom surface of the heat radiation substrate in a specific pattern.
[claim 4] wherein the heat radiation substrate or the housing is formed of a single material comprising Al or Cu or an alloy material containing 50% or more of any one of Al and Cu.
[claim 5] wherein more than 30% of the total surface area of the heat radiation substrate is plated.
Sato teaches:
[claim 3] wherein the heat radiation substrate comprises a metal material and radiation fins are arranged on the bottom surface of the heat radiation substrate in a specific pattern (Fig. 4, 30a with patterned fins 32, para 97 "copper or copper alloy").
[claim 4] wherein the heat radiation substrate or the housing is formed of a single material comprising Al or Cu or an alloy material containing 50% or more of any one of Al and Cu (para 45, "formed of a metal such as aluminum, iron, silver, or copper").
[claim 5] wherein more than 30% of the total surface area of the heat radiation substrate is plated (para 62, "plated with nickel, copper, tin, or the like").
It would have been obvious to one of ordinary skill in the art before the effective filing date of the present application for Rengarajan to include a heat radiation substrate as taught by Sato in order to improve the thermal properties and heat dissipation capacity of the device.
Regarding claims 15, 17, 18, Rengarajan as modified teaches the limitations of claim 1 upon which claim 15, 17 and 18 depend.
Rengarajan does not specifically teach:
[claim 15] wherein the heat radiation substrate comprises one or more wave-formed metal plates structurally bonded to the lower surface thereof.
[claim 17] wherein the heat radiation substrate comprises a cooling system structurally joined thereto and a substrate bonding member used for a water-tight coolant is formed on a joined surface between the heat radiation substrate and the cooling system.
[claim 18] wherein the heat radiation substrate comprises a cooling system structurally joined thereto, and the heat radiation substrate and the cooling system are bonded to each other by using friction stir welding (FSW) so that a coolant of the cooling system is water-tight.
Sato teaches:
[claim 15] wherein the heat radiation substrate comprises one or more wave-formed metal plates structurally bonded to the lower surface thereof (Fig. 4, 21b of 21, as the insulated layer 21a is of crystal construction the metal layer 21b must be formed with a surface pattern for proper adhesion).
[claim 17] wherein the heat radiation substrate comprises a cooling system structurally joined thereto (para 62, "channels 19 intended to facilitate heat exchange for the purpose of cooling the assembly, for example by means of a flow of air or a liquid coolant") and a substrate bonding member used for a water-tight coolant is formed on a joined surface between the heat radiation substrate and the cooling system (para 47 and 50, "The metallized substrate 2 comprises an electrically insulating layer 2 a of ceramic material coated on each of its opposite sides with a metal layer 2 b, 2 c, for example of copper. The metal layers 2 b, 2 c of the metallized substrate 2 can be joined to the insulating layer 2 a by Active Metal Brazing (AMB), Direct Bonded Copper (DBC), or Direct Bonded Aluminium (DBA).").
[claim 18] wherein the heat radiation substrate comprises a cooling system structurally joined thereto, and the heat radiation substrate and the cooling system are bonded to each other by using friction stir welding (FSW) so that a coolant of the cooling system is water-tight (para 47 and 50, "The metallized substrate 2 comprises an electrically insulating layer 2 a of ceramic material coated on each of its opposite sides with a metal layer 2 b, 2 c, for example of copper. The metal layers 2 b, 2 c of the metallized substrate 2 can be joined to the insulating layer 2 a by Active Metal Brazing (AMB), Direct Bonded Copper (DBC), or Direct Bonded Aluminium (DBA).").Product by process.
Furthermore, the present claim is drawn to a device, thus the method of bonding by friction stir welding does not patentably distinguish the claimed invention from that of the modified invention of Rengarajan.
It should be noted that a "product by process claim" is directed to the product per se, no matter how actually made, In re Hirao, 190 USPQ 15 at 17 (footnote 3). See also In re Brown, 173 USPQ 685; In re Luck, 177 USPQ 523; In re Fessmann, 180 USPQ 324; In re Avery, 186 USPQ 161; In re Wertheim, 191 USPQ 90 (209 USPQ 554 does not deal with this issue); and In re Marosi et al., 218 USPQ 289, all of which make it clear that it is the patentability of the final product per se which must be determined in a "product by process" claim, and not the patentability of the process, and that an old or obvious product produced by a new method is not patentable as a product, whether claimed in " product by process" claims or not. Note that applicant has the burden of proof in such cases, as the above caselaw makes clear. See also MPEP 2113 [R-1].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the present application for Rengarajan to include a heat radiation substrate as taught by Sato in order to improve the thermal properties and heat dissipation capacity of the device.
Regarding claim 19, Rengarajan as modified teaches the limitations of claim 1 upon which claim 19 depends.
Rengarajan teaches wherein the heat radiation substrate is formed of a metal material (para 35, base plate), the housing is formed to cover sides of the molding sealing member (Fig. 5, housing 7 covering sides of 800/801) and has a structure in which the upper part thereof is opened (Fig. 5, upper part of structure 100 is open), and a cover comprising penetration holes thereon to expose the terminals is prepared on the upper part of the heat radiation substrate so as to cover the molding sealing member and to be bonded to the upper part of the housing (para 35, cover, Fig. 5, terminals 4 molding 800/801 housing 7).
Response to Arguments
Applicant's arguments filed 30 January 2026 have been fully considered but they are not persuasive.
Regarding claim 1, applicant argues that the Rengarajan – Shafiyan-Rad combination does not teach “a housing disposed on the insulating layer, wherein the housing is in direct contact with the insulating layer” nor “wherein the insulating layer is in direct contact with the heat radiation substrate”. Applicant also argues that the base plate as taught by Rengarajan interpreted as the “heat radiation substrate” is not in contact with the insulation layer 11.
As described in the rejection herein, the new interpretation of Rengarajan teaches a housing (Fig. 5, 7) disposed on the insulating layer (Fig. 5, 11) wherein the housing is in direct contact with the insulating layer (Fig. 5, 7 in direct contact with 11). The new interpretation of Rengarajan teaches wherein the insulating layer (Fig. 5, 11) is in direct contact with the heat radiation substrate (Fig. 5, 112, para 16, "copper; a copper alloy; aluminium; an aluminium alloy; any other metal"). For this interpretation of Rengarajan the base plate is not cited. Noting that Shafiyan-Rad is only being used to teach the housing can be metal as the direct contact limitation is already taught by the base reference.
Conclusion
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/NICHOLAS LELAND HUTSON/Examiner, Art Unit 2818
/JEFF W NATALINI/Supervisory Patent Examiner, Art Unit 2818