Prosecution Insights
Last updated: July 17, 2026
Application No. 18/186,699

METHOD OF PROCESSING SUBSTRATE, METHOD OF MANUFACTURING SEMICONDUCTOR DEVICE, RECORDING MEDIUM, AND SUBSTRATE PROCESSING APPARATUS

Final Rejection §103§112
Filed
Mar 20, 2023
Priority
Mar 24, 2022 — JP 2022-048244
Examiner
HRNJIC, ADIN
Art Unit
2817
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Kokusai Electric Corporation
OA Round
2 (Final)
66%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
73%
With Interview

Examiner Intelligence

Grants 66% — above average
66%
Career Allowance Rate
38 granted / 58 resolved
-2.5% vs TC avg
Moderate +8% lift
Without
With
+7.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
27 currently pending
Career history
102
Total Applications
across all art units

Statute-Specific Performance

§103
93.3%
+53.3% vs TC avg
§102
3.5%
-36.5% vs TC avg
§112
3.2%
-36.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 58 resolved cases

Office Action

§103 §112
Detailed Action This office action is in response to the amendment filed on March 3rd, 2026. Claims 1-9, 11-15, 17, and 19-21 are pending. Claims 17 and 19 have been withdrawn. 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 . Response to Arguments Applicant's arguments filed March 3rd, 2026, have been fully considered but they are not persuasive. Applicant argues (pgs. 9-14, “Remarks”) that the combination of O’Connor and Sasaki fails to teach the limitations presented in amended Claims 1 and 15. However, as seen below, Claim 1 is now rejected by the combination of O’Connor, Schroder, and Maekawa. Claim 15 is now rejected by the combination of Sasaki, O’Connor, Schroder, and Maekawa. Therefore, applicant’s arguments are not persuasive and are moot in view of the new grounds of rejection. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1 and 15 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. In this instance, Claims 1 and 15 recite the limitation “a microwave absorption rate of the action target film is larger than a microwave absorption rate of the treatment target film”. However, applicant’s filed specification recites “a microwave absorption rate of the metal-containing film 2003 is larger than those of other films on the wafer 200 excluding the wafer 200 and the amorphous Si film 2002” ([0072]). Applicant has also defined the metal-containing film 2003 to be the action target film and the amorphous Si film 2002 to be the treatment target film ([0052]-[0053]). In other words, applicant’s specification supports comparing the microwave absorption rate of the action target film 2003 to other layers, such as the SiO film 2001, but not to the treatment target film 2002. Therefore, applicant does not have support for the limitation recited above. 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. Rejection Note: Italicized claim limitations indicate that the corresponding limitations are addressed with a secondary reference/embodiment in an obviousness analysis. Claims 1-9, 11-14, and 20-21 are rejected under 35 U.S.C. 103 as being unpatentable over O’Connor et al. (2020/0211844 A1; hereinafter O’Connor) in view of Schroder et al. (2011/0300676 A1; hereinafter Schroder) and Maekawa et al. (5,950,078 A; hereinafter Maekawa). Regarding Claim 1, O’Connor (fig. 1) teaches a method of processing a substrate ([0038], 10), comprising: loading a substrate (10) in which a treatment target film ([0038], 2) and an action target film ([0038], 1) are formed into a process chamber ([0038], area containing the radiation beam and the substrate); irradiating ([0038]) the action target film (1) with an electromagnetic wave ([0044], laser is used to irradiate 1); and selectively causing the action target film (1) to generate heat by the irradiation with the electromagnetic wave ([0044]) and modifying the treatment target film (2) with a directionality ([0040]-[0045], crystal growth occurs at the interface of 1 and 2 and in the direction of radiation beam 5) by heating the treatment target film (2) with the heat generated by the action target film (1), wherein the electromagnetic wave is microwaves, and wherein a microwave absorption rate of the action target film ([0014], 1 may be formed from nickel) is larger (applicant has defined that a metal-containing film such as nickel has a larger microwave absorption rate than a-Si, see [0053] of filed specification) than a microwave absorption rate of the treatment target film ([0014], 2 may be a-Si). O’Connor doesn’t teach selectively causing the action target film to generate heat. However, Maekawa (fig. 5) teaches selectively (Col. 7, Lines 8-25; only the metal absorptive film is absorbing energy) causing the action target film (Col. 6, Lines 9-18; 24) to generate heat (Col. 6, Lines 19-26). Maekawa also teaches that heating the metal absorptive film controls the crystallization process (Col. 6, Lines 1-8). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the method of O’Connor to selective heating of Maekawa to control the crystallization process. O’Connor doesn’t teach the electromagnetic wave is microwaves. However, Schroder (fig. 1b) teaches the electromagnetic wave is microwaves ([0020]). One of ordinary skill in the art would have found it obvious to try and use microwaves to modify an amorphous silicon layer and yielded the predictable results of properly crystallizing the amorphous silicon ([0045]). Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to use microwaves to crystallize amorphous silicon since this limitation is one of a finite number of identified, predictable potential solutions. This is an appropriate rationale to support a rejection under 35 U.S.C. 103. KSR International Co. v. Teleflex Inc., 550 U.S. 398, 82 USPQ2d 1385 (2007). Regarding Claim 2, O’Connor (fig. 1) teaches the method of claim 1, wherein the treatment target film (2) and the action target film (1) are provided to be in contact with each other (see fig. 1), and wherein the act of modifying includes crystallizing the treatment target film (2) from a surface ([0045], occurs at the interface of 1 and 2) of the treatment target film (2) where the treatment target film (2) and the action target film (1) are in contact with each other. Regarding Claim 3, O’Connor (fig. 1) teaches the method of claim 1, wherein the directionality causes the treatment target film (2) to be crystallized in a direction away (in the direction of the radiation beam 5) from a surface of the treatment target film (2) where the treatment target film (2) and the action target film (1) are in contact with each other. Regarding Claim 4, O’Connor (fig. 1) teaches the method of claim 1, wherein the action target film (1) is formed to cover a surface of the treatment target film (2). Regarding Claim 5, O’Connor (fig. 1) teaches the method of claim 1, wherein the treatment target film (2) is a silicon-containing film ([0050], a-Si). Regarding Claim 6, O’Connor (fig. 1) teaches the method of claim 5, wherein the action target film (1) is a metal-containing film ([0014], can be nickel on a-Si). Regarding Claim 7, O’Connor (fig. 1) teaches the method of claim 6, wherein in the act of modifying, the metal-containing film (1) is caused to generate heat by the irradiation with the electromagnetic wave ([0044]), and the silicon-containing film (2) is crystallized ([0040]-[0045], crystal growth occurs at the interface of 1 and 2 and in the direction of radiation beam 5) by heating the silicon-containing film (2) with the heat generated by the metal-containing film (1). Regarding Claim 8, O’Connor (fig. 1) teaches the method of claim 6, wherein the metal-containing film (1) is a film containing at least one selected from the group of titanium and nickel ([0014], nickel). Regarding Claim 9, O’Connor (fig. 1) teaches the method of claim 2, wherein in the act of modifying, an atom-to-atom distance of the crystallized treatment target film (2) approximates (nickel and crystalline silicon have approximately similar bond lengths) an atom-to-atom distance of the action target film (1) by the heat generated by the action target film (1). Regarding Claim 11, O’Connor (fig. 1) teaches the method of claim 1, further comprising removing the action target film ([0047], 1). Regarding Claim 12, O’Connor (fig. 1) teaches the method of claim 11, wherein the act of removing is performed after the act of modifying ([0047]). Regarding Claim 13, O’Connor (fig. 1) teaches the method of claim 1, wherein a crystal lattice constant of the action target film (1) is the same as or approximates (nickel and a-Si have approximately similar crystal lattice constants) a crystal lattice constant of the treatment target film (2). Regarding Claim 14, O’Connor (fig. 1) teaches a method of manufacturing a semiconductor device ([0019], displays), comprising the method of Claim 1 (see claim 1). Regarding Claim 20, O’Connor (fig. 1) teaches the method of claim 6, wherein the treatment target film (2) is provided to be in contact with the metal-containing film (1), and is a silicon-containing film (a-Si) whose atom-to-atom distance approximates (nickel and crystalline silicon have approximately similar bond lengths) an atom-to-atom distance of the metal- containing film (1). Regarding Claim 21, the combination of O’Connor (fig. 1) and Sasaki teaches the method of claim 20, wherein in the act of modifying, the metal-containing film (O’Connor, 1) is caused to generate heat by the irradiation (O’Connor, [0044]) with the microwaves (Schroder, [0045]), and crystal lattices of the treatment target film (2) are aligned in order from a surface ([0040]-[0045], crystal growth occurs at the interface of 1 and 2)in contact with the metal-containing film (1), such that the silicon-containing film (2) is crystallized to be modified with the directionality ([0040]-[0045], crystal growth occurs in the direction of radiation beam 5). Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Sasaki in view of O’Connor, Maekawa, and Schroder. Regarding Claim 15, Sasaki (fig. 1) teaches: a non-transitory computer-readable recording medium recording a program that causes, by a computer ([0061]), a substrate processing apparatus to perform a process ([0064]-[0065]) comprising: loading a substrate ([0068], 200) in which a treatment target film (200) and an action target film are formed into a process chamber ([0068], 201) of the substrate processing apparatus; irradiating the action target film (200) with an electromagnetic wave ([0071]); and selectively causing the action target film to generate heat by the irradiation with the electromagnetic wave and modifying the treatment target film with a directionality by heating the treatment target film with the heat generated by the action target film, wherein the electromagnetic wave is microwaves, and wherein a microwave absorption rate of the action target film is larger than a microwave absorption rate of the treatment target film. Sasaki does not teach a substrate in which a treatment target film and an action target film are formed, irradiating the action target film with an electromagnetic wave, and selectively causing the action target film to generate heat by the irradiation with the electromagnetic wave and modifying the treatment target film with a directionality by heating the treatment target film with the heat generated by the action target film, and wherein a microwave absorption rate of the action target film is larger than a microwave absorption rate of the treatment target film. However, O’Connor (fig. 1) teaches a substrate ([0038], 10) in which a treatment target film ([0038], 2) and an action target film ([0038], 1) are formed, irradiating ([0038]) the action target film (1) with an electromagnetic wave ([0044], laser is used to irradiate 1), and selectively causing the action target film (1) to generate heat by the irradiation with the electromagnetic wave ([0044]) and modifying the treatment target film (2) with a directionality ([0040]-[0045], crystal growth occurs at the interface of 1 and 2 and in the direction of radiation beam 5) by heating the treatment target film (2) with the heat generated by the action target film (1), and wherein a microwave absorption rate of the action target film ([0014], 1 may be formed from nickel) is larger (applicant has defined that a metal-containing film such as nickel has a larger microwave absorption rate than a-Si, see [0053] of filed specification) than a microwave absorption rate of the treatment target film ([0014], 2 may be a-Si). O’Connor also teaches this approach may form poly-Si in manufacturing displays as it can increase crystallinity without impacting transparency ([0019]). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the computer-readable recording medium of Sasaki to include the use of an action target film of O’Connor to increase crystallinity without affecting transparency. O’Connor doesn’t teach selectively causing the action target film to generate heat. However, Maekawa (fig. 5) teaches selectively (Col. 7, Lines 8-25; only the metal absorptive film is absorbing energy) causing the action target film (Col. 6, Lines 9-18; 24) to generate heat (Col. 6, Lines 19-26). Maekawa also teaches that heating the metal absorptive film controls the crystallization process (Col. 6, Lines 1-8). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the method of O’Connor to selective heating of Maekawa to control the crystallization process. O’Connor doesn’t teach the electromagnetic wave is microwaves. However, Schroder (fig. 1b) teaches the electromagnetic wave is microwaves ([0020]). One of ordinary skill in the art would have found it obvious to try and use microwaves to modify an amorphous silicon layer and yielded the predictable results of properly crystallizing the amorphous silicon ([0045]). Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to use microwaves to crystallize amorphous silicon since this limitation is one of a finite number of identified, predictable potential solutions. This is an appropriate rationale to support a rejection under 35 U.S.C. 103. KSR International Co. v. Teleflex Inc., 550 U.S. 398, 82 USPQ2d 1385 (2007). 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 ADIN HRNJIC whose telephone number is (571)270-1794. The examiner can normally be reached Monday-Friday 8:00 AM - 4:30 PM. 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, Kretelia Graham can be reached at (571) 272-5055. 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. /A.H./Examiner, Art Unit 2817 /Kretelia Graham/Supervisory Patent Examiner, Art Unit 2817
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Prosecution Timeline

Mar 20, 2023
Application Filed
Dec 03, 2025
Non-Final Rejection mailed — §103, §112
Mar 03, 2026
Response Filed
Jun 04, 2026
Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
66%
Grant Probability
73%
With Interview (+7.8%)
3y 4m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 58 resolved cases by this examiner. Grant probability derived from career allowance rate.

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