Prosecution Insights
Last updated: April 19, 2026
Application No. 18/163,272

RESISTIVE RANDOM-ACCESS MEMORY DEVICES WITH COMPOUND NON-REACTIVE ELECTRODES

Non-Final OA §103
Filed
Feb 01, 2023
Examiner
CHOU, SHIH TSUN A
Art Unit
2811
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Tetramem Inc.
OA Round
1 (Non-Final)
76%
Grant Probability
Favorable
1-2
OA Rounds
2y 6m
To Grant
93%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allow Rate
338 granted / 447 resolved
+7.6% vs TC avg
Strong +17% interview lift
Without
With
+17.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
24 currently pending
Career history
471
Total Applications
across all art units

Statute-Specific Performance

§103
48.9%
+8.9% vs TC avg
§102
23.4%
-16.6% vs TC avg
§112
26.6%
-13.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 447 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, claims 1-10, in the reply filed on 12/23/2025 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 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim 1 is rejected under 35 U.S.C. 103 as being unpatentable over Tu (US 2014/0091271) in view of Hwang (US 2018/0190352). Regarding claim 1, Tu discloses, in FIG. 3 and in related text, a resistive random-access memory (RIRAM) device, comprising: a first electrode comprising: a metal nitride layer (208) comprising a metal nitride (TiN); and a metal layer (210) fabricated on the metal nitride layer; a second electrode (214A) comprising a conductive material (Ta); and a switching oxide layer (212) positioned between the first electrode and the second electrode, wherein the switching oxide layer comprises at least one transition metal oxide (HfO), wherein the metal layer comprises a metal (Pt) (see Tu, [0017], [0020], [0023]-[0024]). Tu does not explicitly disclose a metal that is not reactive to the at least one transition metal oxide. Hwang teaches that platinum is not reactive to oxygen ions in transition metal oxide (hafnium oxide) of switch oxide layer (see Hwang, [0045]-[0046], [0057]). Thus Hwang teaches a metal that is not reactive to the at least one transition metal oxide. Tu and Hwang are analogous art because they both are directed to resistive memory devices and one of ordinary skill in the art would have had a reasonable expectation of success to modify Tu with the features of Hwang because they are from the same field of endeavor. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify Tu to include a metal that is not reactive to the at least one transition metal oxide, because platinum has weak or no reactivity with oxygen ions (see Hwang, [0045]). Claims 1-8 are rejected under 35 U.S.C. 103 as being unpatentable over Xia (US 2018/0287058) in view of Hwang (US 2018/0190352). Regarding claim 1, Xia discloses, in FIG. 1B and in related text, a resistive random-access memory (RIRAM) device, comprising: a first electrode comprising: a metal nitride layer (108) comprising a metal nitride (TiN); and a metal layer (130) fabricated on the metal nitride layer; a second electrode (150) comprising a conductive material (Ta); and a switching oxide layer (140) positioned between the first electrode and the second electrode, wherein the switching oxide layer comprises at least one transition metal oxide (HfO2), wherein the metal layer comprises a metal (Pt) (see Xia, [0022]). Xia does not explicitly disclose a metal that is not reactive to the at least one transition metal oxide. Hwang teaches that platinum is not reactive to oxygen ions in transition metal oxide (hafnium oxide) of switch oxide layer (see Hwang, [0045]-[0046], [0057]). Thus Hwang teaches a metal that is not reactive to the at least one transition metal oxide. Xia and Hwang are analogous art because they both are directed to resistive memory devices and one of ordinary skill in the art would have had a reasonable expectation of success to modify Xia with the features of Hwang because they are from the same field of endeavor. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify Xia to include a metal that is not reactive to the at least one transition metal oxide, because platinum has weak or no reactivity with oxygen ions (see Hwang, [0045]). Regarding claim 2, Xia in view of Huang teaches the device of claim 1. Xia discloses wherein the metal nitride (TiN) comprises at least one of titanium nitride or tantalum nitride (see discussion on claim 1 above). Regarding claim 3, Xia in view of Huang teaches the device of claim 1. Xia discloses wherein the metal (Pt) comprises at least one of platinum, palladium, iridium, or ruthenium; Xia teaches the metal that is not reactive to the at least one transition metal oxide (see discussion on claim 1 above). Regarding claims 4-6, Xia in view of Huang teaches the device of claim 3. Xia discloses wherein the metal layer (130, 1~4 nm) is thinner than the metal nitride layer (108, 10~100 nm), wherein a thickness of the metal layer is between 3 nm and 10 nm, wherein a thickness of the metal nitride layer is between 20 nm and 50 nm (see Xia, [0022]). Regarding claim 7, Xia in view of Huang teaches the device of claim 1. Xia discloses wherein the at least one transition metal oxide (HfO2) comprises at least one of HfOx or TaOy, wherein x≤2.0, and wherein y≤2.5 (see discussion on claim 1 above). Regarding claim 8, Xia in view of Huang teaches the device of claim 1. Xia discloses wherein the conductive material (Ta) in the second electrode (150) comprises tantalum (see discussion on claim 1 above). Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Xia in view of Hwang, and further in view of Nabatame (US 2017 /0346006). Regarding claim 9, Xia in view of Huang teaches the device of claim 1. Xia discloses the switching oxide layer (140) and the second electrode (150) (see Xia, FIG. 1B, [0022]). Xia does not explicitly disclose an interface layer positioned between the switching oxide layer and the second electrode, wherein the interface layer comprises aluminum oxide. Nabatame teaches an interface layer (13) positioned between the switching oxide layer (12) and the second electrode (14), wherein the interface layer comprises aluminum oxide (see Nabatame, FIG. 1, [0037]). Xia and Nabatame are analogous art because they both are directed to resistive memory devices and one of ordinary skill in the art would have had a reasonable expectation of success to modify Xia with the features of Nabatame because they are from the same field of endeavor. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify Xia to include an interface layer positioned between the switching oxide layer and the second electrode, wherein the interface layer comprises aluminum oxide, as taught by Nabatame, to provide low forming voltage and small varication among memories (see Nabatame, [0050]). Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Xia in view of Hwang, and further in view of Yang (US 2019/0303104). Regarding claim 10, Xia in view of Huang teaches the device of claim 1. Xia discloses the metal nitride layer (see discussion on claim 1 above). Xia does not explicitly disclose an adhesive layer comprising at least one of titanium or tantalum, wherein the metal nitride layer is fabricated on the adhesive layer. Yang teaches an adhesive layer (506, titanium) comprising at least one of titanium or tantalum, wherein the metal nitride layer (530, titanium nitride) is fabricated on the adhesive layer (see Yang, FIG. 5, [0061]-[0062]). Xia and Yang are analogous art because they both are directed to resistive memory devices and one of ordinary skill in the art would have had a reasonable expectation of success to modify Xia with the features of Yang because they are from the same field of endeavor. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify Xia to include an adhesive layer comprising at least one of titanium or tantalum, wherein the metal nitride layer is fabricated on the adhesive layer, as taught by Yang, to create an adhesion surface to an oxide layer below (see Yang, [0061]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SHIH TSUN A CHOU whose telephone number is (408)918-7583. The examiner can normally be reached M-F 8:00-16:00 Arizona Time. 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, Lynne Gurley can be reached at (571) 272-1670. 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. /SHIH TSUN A CHOU/Primary Examiner, Art Unit 2811
Read full office action

Prosecution Timeline

Feb 01, 2023
Application Filed
Feb 08, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

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

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Prosecution Projections

1-2
Expected OA Rounds
76%
Grant Probability
93%
With Interview (+17.1%)
2y 6m
Median Time to Grant
Low
PTA Risk
Based on 447 resolved cases by this examiner. Grant probability derived from career allow rate.

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