Prosecution Insights
Last updated: April 19, 2026
Application No. 18/317,951

MRAM DEVICE WITH TRAPEZOID SHAPED ELECTRODES

Non-Final OA §102§103§112
Filed
May 16, 2023
Examiner
CHOU, SHIH TSUN A
Art Unit
2811
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
International Business Machines Corporation
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

§102 §103 §112
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 1-13, in the reply filed on 10/29/2025 is acknowledged. Claims 14-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 10/29/2025. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the limitation “the second electrode comprises a side surface comprising a width at a middle section of the second electrode greater than a width at a lower surface of the second electrode, and the width at the middle section of the second electrode greater than a width at an upper surface of the second electrode” of claim 12 must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Objections Claim 6 is objected to because of the following informalities: the text a encapsulation layer” is suggested to be changed to “an encapsulation layer” for clarity. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim 10 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 10 recites the limitation "the bottom electrode" in line 3. There is insufficient antecedent basis for this limitation in the claim. The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. The following is a quotation of pre-AIA 35 U.S.C. 112, fourth paragraph: Subject to the following paragraph [i.e., the fifth paragraph of pre-AIA 35 U.S.C. 112], a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claim 12 is rejected under 35 U.S.C. 112(d) or pre-AIA 35 U.S.C. 112, 4th paragraph, as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends. Claim 12 depends on claim 11. Claim 11 recites a second electrode as a trapezoid. However, claim 12 recites the second electrode having a shape with a middle section having a width greater than widths of upper surface and lower surface, that is, claim 12 is directed to a hexagon. Claim 12 fails to further limit the subject matter of claim 11. Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements. Claim Rejections - 35 USC § 102 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 the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1-5 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Yun (US 2019/0140163). Regarding claim 1, Yun discloses, in FIGS. 2-3 and in related text, a semiconductor device comprising: a magnetic tunnel junction (MTJ) stack (including at least MTJP), wherein a cross section of a bottom electrode (BE) of the MTJ stack comprises a trapezoid profile (see Yun, [0022], [0039], [0051]: the width of the structure is tapered aways from substrate below, thus the structure has a trapezoidal cross-section profile). Regarding claim 2, Yun discloses the device of claim 1. Yun discloses the MTJ stack comprises vertically aligned layers of a top electrode (TE), a free layer (MS2), a tunneling barrier (TBP), a reference layer (MS1) and the bottom electrode (BE) (see Yun, FIG. 3, [0019], [0022]-[0023]). Regarding claim 3, Yun discloses the device of claim 1. Yun discloses the bottom electrode (BE) comprises a tapered side surface comprising a width at an upper surface of the bottom electrode less than a width at a lower surface of the bottom electrode (see Yun, FIG. 3, [0039] and discussion on claim 1 above). Regarding claim 4, Yun discloses the device of claim 1. Yun discloses a cross section of a top electrode (TE) of the stack comprises a trapezoid profile (see Yun, FIG. 3, [0039] and discussion on claim 1 above). Regarding claim 5, Yun discloses the device of claim 4. Yun discloses the top electrode (TE) comprises a tapered side surface comprising a width at an upper surface of the top electrode less than a width at a lower surface of the top electrode (see Yun, FIG. 3, [0039] and discussion on claim 1 above). Claims 1 and 6 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Huang (US 2017/0294576). Regarding claim 1, Huang discloses, in FIGS. 10B and 13, and in related text, a semiconductor device comprising: a magnetic tunnel junction (MTJ) stack (including at least 810), wherein a cross section of a bottom electrode (610U’) of the MTJ stack comprises a trapezoid profile (see Huang, [0027], [0031], [0034]). Regarding claim 6, Huang discloses the device of claim 1. Huang discloses a encapsulation layer (950) surrounding vertical side surfaces of a free layer, a tunneling barrier and a reference layer (of MTJ 810) (see Huang, FIG. 13, [0034], [0040]). Claims 7-9 and 11 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Yun (US 2019/0140163). Regarding claim 7, Yun discloses, in FIGS. 1-3 and in related text, a semiconductor device comprising: a lower word line (WL); and a first electrode (BE) above and (electrically) connected to the lower word line, wherein a cross section of an electrode (BE or TE) comprises a trapezoid profile (see Yun, [0017], [0022], [0039], [0051]: the width of the structure is tapered aways from substrate below, thus the structure has a trapezoidal cross-section profile). Regarding claim 8, Yun discloses the device of claim 7. Yun discloses a magnetic tunnel junction (MTJ) stack (including at least MTJP) above and connected to the first electrode (BE) (see Yun FIG. 3, [0022]-[0023], [0051]). Regarding claim 9, Yun discloses the device of claim 8. Yun discloses the MTJ stack comprises vertically aligned layers of a top electrode (TE), a free layer (MS2), a tunneling barrier (TBP), a reference layer (MS1) and the first electrode (BE) (see Yun, FIG. 3, [0019], [0022]-[0023]). Regarding claim 11, Yun discloses the device of claim 8. Yun discloses cross section of a second electrode (TE) of the stack comprises a trapezoid profile, wherein the second electrode is above and connected to the MTJ stack (MTJP) (see Yun, [0022]-[0023], [0039] and discussion on claim 7 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. 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. Claims 7-9 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Wang (US 2010/0302838) in view of Huang (US 2017/0294576). Regarding claim 7, Wang discloses, in FIG. 3 and in related text, a semiconductor device comprising: a lower word line (330); and a first electrode (bottom electrode 150) above and connected (through transistor 310) to the lower word line (see Wang, [0020]). Wang does not explicitly disclose wherein a cross section of an electrode comprises a trapezoid profile. Huang teaches wherein a cross section of an electrode (bottom electrode 610U’) comprises a trapezoid profile (see Huang, FIGS. 10B and 13, [0027], [0031], [0034]). Wang and Huang are analogous art because they both are directed to magnetic memory devices and one of ordinary skill in the art would have had a reasonable expectation of success to modify Wang with the features of Huang 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 Wang to include wherein a cross section of an electrode comprises a trapezoid profile, as taught by Huang, in order to form bottom electrode and interconnection via feature simultaneously with inherited good physical contact (see Huang, [0029]). Regarding claim 8, Wang in view of Huang teaches the device of claim 7. Wang discloses a magnetic tunnel junction (MTJ) stack above and connected to the first electrode (bottom electrode 150) (see Wang, FIG. 3, [0006], [0020]). Regarding claim 9, Wang in view of Huang teaches the device of claim 8. Wang discloses the MTJ stack comprises vertically aligned layers of a top electrode (320), a free layer (130), a tunneling barrier (120), a reference layer (110) and the first electrode (150) (see Wang, FIG. 3, [0006], [0020]). Regarding claim 13, Wang in view of Huang teaches the device of claim 9. Huang teaches an encapsulation layer (950) surrounding vertical side surfaces of the free layer, the tunneling barrier and the reference layer (of MTJ 810) (see Huang, FIG. 13, [0034], [0040]), with at least the same analogous prior art and field of endeavor statement and the same motivation as provided for in claim 7, and to provide protection for memory stack to reduce current leakage (see Huang, [0040]). 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

May 16, 2023
Application Filed
Dec 08, 2025
Non-Final Rejection — §102, §103, §112 (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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