Prosecution Insights
Last updated: April 19, 2026
Application No. 18/179,588

SEED LAYER FOR ENHANCING TUNNEL MAGNETORESISTANCE WITH PERPENDICULARLY MAGNETIZED HEUSLER FILMS

Non-Final OA §103
Filed
Mar 07, 2023
Examiner
SON, ERIKA HEERA
Art Unit
2893
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
68%
Grant Probability
Favorable
1-2
OA Rounds
3y 6m
To Grant
27%
With Interview

Examiner Intelligence

Grants 68% — above average
68%
Career Allow Rate
13 granted / 19 resolved
At TC average
Minimal -42% lift
Without
With
+-41.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
34 currently pending
Career history
53
Total Applications
across all art units

Statute-Specific Performance

§103
58.0%
+18.0% vs TC avg
§102
15.2%
-24.8% vs TC avg
§112
21.9%
-18.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 19 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 with traverse of Species 1 (which reads on Fig. 1) in the reply filed on 12/29/2025 is acknowledged. Species 1 (Fig. 1) encompasses claims 1-3, 5-15, and 17-25. Claims 4 and 16 are withdrawn. In response to Applicant’s traversal (in the 12/29/2025 reply), as set forth in the Restriction Requirement mailed on 11/10/2025, Species 1 and Species 2 include mutually exclusive characteristics. Species 1 includes a first magnetic layer 220 comprising a storage layer, and a second magnetic layer 228 comprising a reference layer. Species 2 includes a second magnetic layer 328 comprising a storage layer, and a first magnetic layer 220 comprising a reference layer. In addition, these species are not obvious variants of each other based on the current record. Claims 4 and 16 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Claim Rejections - 35 USC § 103 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. 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. Claims 1-3, 5-15, and 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US 20200105999) in view of Inubushi et al. (US 20200303634). Regarding claim 1, Jeong teaches, in Fig. 9, a magnetic random access memory (MRAM) stack ([0001], [0014]) comprising: a first magnetic layer comprising a Heusler compound ("Heusler"; [0029]); and one or more seed layers ("CTL/Seed", [0029]) comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound ([0022]) and enhance a tunnel magnetoresistance (TMR) of the MRAM stack ([0030]), wherein the first magnetic layer ("Heusler") is formed over the multi-layer templating structure (CTL/Seed) (see Fig. 9), the multi-layer templating structure comprising: a first layer (MnxN, [0022]), and a layer of a second binary alloy having a cesium-chloride (CsCl) structure (CoAl, [0029], CoAl has the CsCl crystal structure), wherein the second binary alloy overlays the first layer (CoAl on top of MnxN layer). Jeong does not teach that the first layer is a layer of a first binary alloy comprising tungsten-aluminum (WAl). In a similar field of endeavor, Inubushi teaches that the first layer (15, Fig. 1, [0038]; 15 is a crystal orientation layer that is the first layer that is underneath second layer 20) “comprises at least one of, for instance, Ag, Au, Cu, Cr, V, Al, W, and Pt” ([0038]), for the purpose of “controlling the crystal orientation of the upper layers” ([0038]). Based on Inubushi’s teachings of the list of materials for the first layer 15 described above, one of ordinary skill in the art would have experimented and used an alloy comprising tungsten-aluminum, as choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success would be considered as an obvious to try rationale (see MPEP §2143-I E). A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 82 USPQ2d 1321 (Fed. Cir. 2007). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the material of the lower layer of the multi-layer templating structure of Jeong with the binary alloy comprising tungsten-aluminum (WAl) of Inubushi, in order to control the crystal orientation of the upper layers ([0038]). Regarding claim 2, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches, in Fig. 9, a second magnetic layer (“CoFeB”; [0029]); and a tunnel barrier (“MgO”, [0029]) positioned between, and in contact with, one or more of the first magnetic layer (“Heusler”) and the second magnetic layer (“CoFeB”) (see Fig. 9, both), wherein: the first magnetic layer (“Heusler”) comprises a storage layer ([0029], “switchable layer”); the second magnetic layer (“CoFeB”) comprises a reference layer ([0029]); and the first magnetic layer (“Heusler”), the tunnel barrier (“MgO”), and the second magnetic layer (“CoFeB”) define a magnetic tunnel junction (MTJ) ([0029]). Regarding claim 3, Jeong in view of Inubushi teaches the limitations of claim 2. Jeong further teaches, in Fig. 9, that the tunnel barrier (“MgO”) is formed from MgO ([0029]). Regarding claim 5, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the first magnetic layer (“Heusler”; Fig. 9) has magnetization which is orientated perpendicular to the thickness of the film and a thickness less than 5 nanometers (nm) ([0004], “The thinnest layers to date are for the Heusler compound Mn3Ge, for which layers as thin as 5 nm showed perpendicular magnetic anisotropy…”). Regarding claim 6, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the first magnetic layer (“Heusler”) is formed from compounds of Mn3Z, wherein: Z is an element selected from the group consisting of germanium (Ge), tin (Sn), and antimony (Sb) ([0022]). Regarding claim 7, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the Heusler compound is a ternary Heusler compound selected from the manganese-cobalt-tin group consisting of Mn3.3-xCo1.1-ySn, in which 0.2 ≤ x ≤ 1.2 and y ≤ 1.0 ([0022]). Regarding claim 8, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the Heusler compound is chosen from the group consisting of Mn3Al, Mn3Ga, Mn3In, Mn2FeSb, Mn3CoAl, Mn2CoGe, Mn2CoSi, Mn2CuSi, Mn2CoSn, Co2CrAl, Co2CrSi, Co2MnSb, and Co2MnSi ([0004], Mn3Ga and Mn2CoSn). Regarding claim 9, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the Heusler compound is Mn3Ge ([0022]). Regarding claim 10, Jeong in view of Inubushi teaches the limitations of claim 1. Jeong further teaches that the multi-layer templating structure (“CTL/Seed”; Fig. 9) comprises: a plurality of materials having the CsCl structure ([0022], “The chemical templating layer can be deposited at room temperature and is chemically ordered [i.e., the formation of alternating atomic layers of Co and Ga or Ge or Sn or Al]”). Regarding claim 11, Jeong in view of Inubushi teaches the limitations of claim 10. Jeong further teaches, in Fig. 9, that the second binary alloy having the CsCl structure (“CoAl”) comprises: a CsCl structure as represented by A1-xEx, wherein A is a transition metal element and E is a main group element, with x being in a range from 0.45 to 0.55 (see Jeong claims 12 and 16). Regarding claim 12, Jeong in view of Inubushi teaches the limitations of claim 11. Jeong further teaches, in Fig. 9, that the multi-layer templating structure comprises cobalt-aluminum (CoAl) (“CoAl”; Fig. 9). Regarding claim 13, Jeong teaches a method of fabricating a magnetic random access memory (MRAM) stack ([0001], [0014]) comprising: forming one or more seed layers (“CTL/Seed”; [0022], [0029]) comprising: forming a multi-layer templating structure (“CTL/Seed”; [0022]) above a substrate (CIPT Substrate) ([0014]), wherein the multi-layer templating structure (“CTL/Seed”) includes a crystalline structure configured to enhance a tunnel magnetoresistance (TMR) of the MRAM stack ([0030]), wherein the forming the multi-layer templating structure ([0022], [0026]) comprises: forming a first layer (MnxN, [0022]); and forming a layer of a second binary alloy having a cesium-chloride (CsCl) structure (CoAl, [0026], [0029], CoAl has the CsCl crystal structure), wherein the second binary alloy overlays the first layer (CoAl on top of MnxN layer); and forming a first magnetic layer ("Heusler"; [0029]) comprising: templating a Heusler compound through the multi-layer templating structure ([0022]). Jeong does not teach that the first layer is a layer of a first binary alloy comprising tungsten-aluminum (WAl). In a similar field of endeavor, Inubushi teaches that the first layer (15, Fig. 1, [0038]; 15 is a crystal orientation layer that is the first layer that is underneath second layer 20) “comprises at least one of, for instance, Ag, Au, Cu, Cr, V, Al, W, and Pt” ([0038]), for the purpose of “controlling the crystal orientation of the upper layers” ([0038]). Based on Inubushi’s teachings of the list of materials for the first layer 15 described above, one of ordinary skill in the art would have experimented and used an alloy of tungsten and aluminum, as choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success would be considered as an obvious to try rationale (see MPEP §2143-I E). A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 82 USPQ2d 1321 (Fed. Cir. 2007). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the material of the lower layer of the multi-layer templating structure of Jeong with the binary alloy comprising tungsten-aluminum (WAl) of Inubushi, in order to control the crystal orientation of the upper layers ([0038]). Regarding claim 14, Jeong in view of Inubushi teaches the limitations of claim 13. Jeong further teaches templating the Heusler compound (“Heusler”) over the multi-layer templating structure (“CTL/Seed”) ([0022]). Regarding claim 15, Jeong in view of Inubushi teaches the limitations of claim 13. Jeong further teaches, in Fig. 9, forming a tunnel barrier (“MgO”, [0029]) over the first magnetic layer (“Heusler”); and forming a second magnetic layer (“CoFeB”; [0029]) over the tunnel barrier (“MgO”), thereby positioning the tunnel barrier (“MgO”) between, and in contact with, the first magnetic layer (“Heusler”) and the second magnetic layer (“CoFeB”) (see Fig. 9), wherein: the first magnetic layer (“Heusler”) defines a storage layer ([0029], “switchable layer”); the second magnetic layer (“CoFeB”) define a reference layer ([0029]); and the first magnetic layer (“Heusler”), the tunnel barrier (“MgO”), and the second magnetic layer (“CoFeB”) define a magnetic tunnel junction (MTJ) ([0029]). Regarding claim 17, Jeong in view of Inubushi teaches the limitations of claim 13. Jeong further teaches, in Fig. 9, that the forming the layer of the second binary alloy having the CsCl structure (“CoAl”) comprises one or more of: forming the CsCl structure as represented by A1-xEx, wherein A is a transition metal element and E is a main group element, with x being in a range from 0.45 to 0.55 (see Jeong claims 12 and 16); and forming the multi-layer templating structure (“CTL/Seed”) with a binary alloy including cobalt-aluminum (CoAl) (“CoAl”) (Fig. 9). Regarding claim 18, Jeong in view of Inubushi teaches the limitations of claim 13. Jeong further teaches that the templating the Heusler compound comprises templating the first magnetic layer (“Heusler”) from compounds of Mn3Z, wherein: Z is an element selected from the group consisting of germanium (Ge), tin (Sn), and antimony (Sb) ([0022]). Regarding claim 19, Jeong in view of Inubushi teaches the limitations of claim 13. Jeong further teaches that the templating the Heusler compound comprises one or more of: templating the first magnetic layer (“Heusler”) from a ternary Heusler compound selected from the manganese-cobalt-tin group consisting of Mn3.3-xCo1.1-ySn, in which 0.2 ≤ x ≤ 1.2 and y ≤ 1.0 ([0022]). templating the first magnetic layer (“Heusler”) from the Heusler compound chosen from the group consisting of Mn3Al, Mn3Ga, Mn3In, Mn2FeSb, Mn3CoAl, Mn2CoGe, Mn2CoSi, Mn2CuSi, Mn2CoSn, Co2CrAl, Co2CrSi, Co2MnSb, and Co2MnSi ([0004], Mn3Ga and Mn2CoSn); and templating the first magnetic layer (“Heusler”) from the Heusler compound of Mn3Ge ([0022]). Claims 20-24 are rejected under 35 U.S.C. 103 as being unpatentable over Vetrò et al. (US 20130119495) in view of Jeong et al. (US 20200105999) and Inubushi et al. (US 20200303634). Regarding claim 20, Vetrò teaches, in Fig. 5, a magnetic random-access memory (MRAM) array ([0040]), comprising: a plurality of bit lines (BL0-BL2) and a plurality of corresponding complementary bit lines (BL0n-BL2n) forming a plurality of bit line-complementary bit line pairs (BL0/BL0n, BL1/BL1n, BL2/BL2n, . . . ; [0040]); a plurality of word lines (WL0-WL2) intersecting the plurality of bit line pairs at a plurality of cell locations (located at 302) (see Fig. 5); a plurality of MRAM cells (302, [0040]) located at each cell location of the plurality of cell locations (see Fig. 5), each MRAM cell of the plurality of MRAM cells being electrically connected to a corresponding bit line of the plurality of bit lines and selectively interconnected to a corresponding one of the plurality of the complementary bit lines under control of a corresponding one of the word lines of the plurality of word lines ([0040], see Fig. 5, for example, top left 302 electrically connected to BL0 and selectively interconnected to corresponding complementary bit line BL0n under control of WL0), Vetrò does not teach that each MRAM cell of the plurality of MRAM cells comprises: a first magnetic layer comprising a Heusler compound; and one or more seed layers comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound and enhance a tunnel magnetoresistance (TMR) of each MRAM cell of the plurality of MRAM cells, wherein the first magnetic layer is formed over the multi-layer templating structure, the multi-layer templating structure comprising: a layer of a first binary alloy comprising tungsten-aluminum (WAl); and a layer of a second binary alloy having a cesium-chloride (CsCl) structure, wherein the second binary alloy overlays the first binary alloy. Jeong teaches, in Fig. 9, a magnetic random access memory (MRAM) cell ([0001], [0014]) comprising: a first magnetic layer comprising a Heusler compound ("Heusler"; [0029]); and one or more seed layers ("CTL/Seed", [0029]) comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound ([0022]) and enhance a tunnel magnetoresistance (TMR) of the MRAM stack ([0030]), wherein the first magnetic layer ("Heusler") is formed over the multi-layer templating structure (CTL/Seed) (see Fig. 9), the multi-layer templating structure comprising: a first layer (MnxN, [0022]), and a layer of a second binary alloy having a cesium-chloride (CsCl) structure (CoAl, [0029], CoAl has the CsCl crystal structure), wherein the second binary alloy overlays the first layer (CoAl on top of MnxN layer), in order to “be able to use ultra-thin tetragonal Heusler compounds as magnetic electrodes switchable by STT for MRAM” ([0004]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify each MRAM cell of Vetrò with the MRAM cell of Jeong, in order to be able to use ultra-thin tetragonal Heusler compounds as magnetic electrodes switchable by STT for MRAM ([0004]). Vetrò in view of Jeong does not teach that the first layer is a layer of a first binary alloy comprising tungsten-aluminum (WAl). In a similar field of endeavor, Inubushi teaches that the first layer (15, Fig. 1, [0038]; 15 is a crystal orientation layer that is the first layer that is underneath second layer 20) “comprises at least one of, for instance, Ag, Au, Cu, Cr, V, Al, W, and Pt” ([0038]), for the purpose of “controlling the crystal orientation of the upper layers” ([0038]). Based on Inubushi’s teachings of the list of materials for the first layer 15 described above, one of ordinary skill in the art would have experimented and used an alloy of tungsten and aluminum, as choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success would be considered as an obvious to try rationale (see MPEP §2143-I E). A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 82 USPQ2d 1321 (Fed. Cir. 2007). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the material of the lower layer of the multi-layer templating structure of Jeong with the binary alloy comprising tungsten-aluminum (WAl) of Inubushi, in order to control the crystal orientation of the upper layers ([0038]). Regarding claim 21, Vetrò in view of Jeong and Inubushi teaches the limitations of claim 20. Jeong further teaches, in Fig. 9, a second magnetic layer (“CoFeB”; [0029]); and a tunnel barrier (“MgO”, [0029]) positioned between, and in contact with, one or more of the first magnetic layer (“Heusler”) and the second magnetic layer (“CoFeB”) (see Fig. 9, both), wherein: the first magnetic layer (“Heusler”) comprises one of a storage layer and a reference layer ([0029], storage layer, “switchable layer”); the second magnetic layer (“CoFeB”) comprises one of a reference layer and a storage layer ([0029], reference layer) in opposition to the first magnetic layer (“Heusler”) (see Fig. 9); and the first magnetic layer (“Heusler”), the tunnel barrier (“MgO”), and the second magnetic layer (“CoFeB”) define a magnetic tunnel junction (MTJ) ([0029]). Regarding claim 22, Vetrò in view of Jeong and Inubushi teaches the limitations of claim 20. Vetrò further teaches, in Fig. 5, that each word line of the plurality of word lines (WL0-WL2) is configured to receive one or more signals to cause a first subset of the plurality of MRAM cells (302) to store logical ones and a second subset of the plurality of MRAM cells (302) to store logical zeroes ([0039]-[0040]); and each bit line-complementary bit line pair of the plurality of bit line-complementary bit line pairs (BL0/BL0n, BL1/BL1n, BL2/BL2n) is configured to read the stored logical ones and zeroes ([0039]-[0040]). Regarding claim 23, Vetrò teaches a computer system ([0041]) comprising: one or more processing devices ([0041], personal computer); one or more memory devices (MRAM memory chip, [0040]-[0041]) communicatively and operably coupled to the one or more processing devices ([0041]), at least one memory device of the one or more memory devices comprising one or more magnetic random access memory (MRAM) devices (memory cell 302, [0040]). Vetrò does not teach that each MRAM device of the one or more MRAM devices comprises: a first magnetic layer comprising a Heusler compound; and one or more seed layers comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound and enhance a tunnel magnetoresistance (TMR) of each MRAM device of the one or more MRAM devices, wherein the first magnetic layer is formed over the multi-layer templating structure, the multi-layer templating structure comprising: a layer of a first binary alloy comprising tungsten-aluminum (WAl); and a layer of a second binary alloy having a cesium-chloride (CsCl) structure, wherein the second binary alloy overlays the first binary alloy. Jeong teaches, in Fig. 9, a magnetic random access memory (MRAM) device ([0001], [0014]) comprising: a first magnetic layer comprising a Heusler compound ("Heusler"; [0029]); and one or more seed layers ("CTL/Seed", [0029]) comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound ([0022]) and enhance a tunnel magnetoresistance (TMR) of the MRAM stack ([0030]), wherein the first magnetic layer ("Heusler") is formed over the multi-layer templating structure (CTL/Seed) (see Fig. 9), the multi-layer templating structure comprising: a first layer (MnxN, [0022]), and a layer of a second binary alloy having a cesium-chloride (CsCl) structure (CoAl, [0029], CoAl has the CsCl crystal structure), wherein the second binary alloy overlays the first layer (CoAl on top of MnxN layer), in order to “be able to use ultra-thin tetragonal Heusler compounds as magnetic electrodes switchable by STT for MRAM” ([0004]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify each MRAM device of Vetrò with the MRAM cell of Jeong, in order to be able to use ultra-thin tetragonal Heusler compounds as magnetic electrodes switchable by STT for MRAM ([0004]). Vetrò in view of Jeong does not teach that the first layer is a layer of a first binary alloy comprising tungsten-aluminum (WAl). In a similar field of endeavor, Inubushi teaches that the first layer (15, Fig. 1, [0038]; 15 is a crystal orientation layer that is the first layer that is underneath second layer 20) “comprises at least one of, for instance, Ag, Au, Cu, Cr, V, Al, W, and Pt” ([0038]), for the purpose of “controlling the crystal orientation of the upper layers” ([0038]). Based on Inubushi’s teachings of the list of materials for the first layer 15 described above, one of ordinary skill in the art would have experimented and used an alloy of tungsten and aluminum, as choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success would be considered as an obvious to try rationale (see MPEP §2143-I E). A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 82 USPQ2d 1321 (Fed. Cir. 2007). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the material of the lower layer of the multi-layer templating structure of Jeong with the binary alloy comprising tungsten-aluminum (WAl) of Inubushi, in order to control the crystal orientation of the upper layers ([0038]). Regarding claim 24, Vetrò in view of Jeong and Inubushi teaches the limitations of claim 23. Jeong further teaches, in Fig. 9, that the each MRAM device of the one or more MRAM devices further comprises: a second magnetic layer (“CoFeB”; [0029]); and a tunnel barrier (“MgO”, [0029]) positioned between, and in contact with, one or more of the first magnetic layer (“Heusler”) and the second magnetic layer (“CoFeB”) (see Fig. 9, both), wherein: the first magnetic layer (“Heusler”) comprises one of a storage layer and a reference layer ([0029], storage layer, “switchable layer”); the second magnetic layer (“CoFeB”) comprises one of a reference layer and a storage layer ([0029], reference layer) in opposition to the first magnetic layer (“Heusler”) (see Fig. 9); and the first magnetic layer (“Heusler”), the tunnel barrier (“MgO”), and the second magnetic layer (“CoFeB”) define a magnetic tunnel junction (MTJ) ([0029]). Claim 25 is rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US 20200105999) in view of Inubushi et al. (US 20200303634) and Vetrò et al. (US 20130119495). Regarding claim 25, Jeong teaches, in Fig. 9, a magnetic random-access memory (MRAM) stack ([0001], [0014]) comprising: a first magnetic layer comprising a Heusler compound ("Heusler"; [0029]); and one or more seed layers ("CTL/Seed", [0029]) comprising: a multi-layer templating structure comprising a crystalline structure configured to template the Heusler compound ([0022]) and enhance a tunnel magnetoresistance (TMR) of the MRAM stack ([0030]), wherein the first magnetic layer ("Heusler") is formed over the multi-layer templating structure (CTL/Seed) (see Fig. 9), the multi-layer templating structure comprising: a first layer (MnxN, [0022]), and a layer of a second binary alloy having a cesium-chloride (CsCl) structure (CoAl, [0029], CoAl has the CsCl crystal structure), wherein the second binary alloy overlays the first layer (CoAl on top of MnxN layer). Jeong does not teach that the first layer is a layer of a first binary alloy comprising tungsten-aluminum (WAl). In a similar field of endeavor, Inubushi teaches that the first layer (15, Fig. 1, [0038]; 15 is a crystal orientation layer that is the first layer that is underneath second layer 20) “comprises at least one of, for instance, Ag, Au, Cu, Cr, V, Al, W, and Pt” ([0038]), for the purpose of “controlling the crystal orientation of the upper layers” ([0038]). Based on Inubushi’s teachings of the list of materials for the first layer 15 described above, one of ordinary skill in the art would have experimented and used an alloy of tungsten and aluminum, as choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success would be considered as an obvious to try rationale (see MPEP §2143-I E). A person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. Pfizer, Inc. v. Apotex, Inc., 480 F.3d 1348, 82 USPQ2d 1321 (Fed. Cir. 2007). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the material of the lower layer of the multi-layer templating structure of Jeong with the binary alloy comprising tungsten-aluminum (WAl) of Inubushi, in order to control the crystal orientation of the upper layers ([0038]). Jeong in view of Inubushi does not teach a magnetic random-access memory (MRAM) device comprising: a plurality of the MRAM stacks. In a similar field of endeavor, Vetrò teaches, in Fig. 5, a magnetic random-access memory (MRAM) device ([0040]), comprising: a plurality of MRAM stacks (302, [0040]), in order to construct MRAM memory chips and increase total storage capacity of the device ([0040]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify the MRAM stack of Jeong in view of Inubushi with the MRAM device of Vetrò, in order to construct MRAM memory chips and increase total storage capacity of the device. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ERIKA HEERA SON whose telephone number is 703-756-4644. The examiner can normally be reached Monday - Friday 11:30-8:30 PM ET. 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, Yara Green can be reached on 571-270-3035. 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. /ERIKA H SON/Examiner, Art Unit 2893 /YARA B GREEN/Supervisor Patent Examiner, Art Unit 2893
Read full office action

Prosecution Timeline

Mar 07, 2023
Application Filed
Feb 25, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12599988
PROCESS OF MAKING COMPONENTS FOR ELECTRONIC AND OPTICAL DEVICES USING LASER PROCESSING
2y 5m to grant Granted Apr 14, 2026
Patent 12593551
DISPLAY DEVICE USING MICRO LED AND MODULAR DISPLAY DEVICE USING SAME
2y 5m to grant Granted Mar 31, 2026
Patent 12557416
LIGHT RECEPTION ELEMENT AND ELECTRONIC DEVICE
2y 5m to grant Granted Feb 17, 2026
Patent 12543595
LIGHT-EMITTING ASSEMBLY, DISPLAY DEVICE, AND METHOD FOR MAKING LIGHT-EMITTING ASSEMBLY
2y 5m to grant Granted Feb 03, 2026
Patent 12532555
Method for Producing a Multipixel Detector
2y 5m to grant Granted Jan 20, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

1-2
Expected OA Rounds
68%
Grant Probability
27%
With Interview (-41.7%)
3y 6m
Median Time to Grant
Low
PTA Risk
Based on 19 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month