Prosecution Insights
Last updated: April 19, 2026
Application No. 18/317,989

MRAM DEVICE WITH HEXAGONAL 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 11/03/2025 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 Claims 14-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim.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 11/03/2025. 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. Claims 8-9 and 13 are 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 8 depends on claim 7. Claim 8 recites the limitation “a magnetic tunnel junction (MTJ) stack” in line 2. It is not clear whether the limitation refers to “a magnetic tunnel junction (MTJ) stack” in line 3 of claim 7. Claim 9 recites the limitation "the bottom electrode" in line 3. There is insufficient antecedent basis for this limitation in the claim. 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. Claim 1 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Xia (US 2010/0054028). Regarding claim 1, Xia discloses, in FIG. 1 and in related text, a semiconductor device comprising: a magnetic tunnel junction (MTJ) stack (including MTJ 105), wherein a cross section of a bottom electrode (180) of the stack comprises a hexagonal profile (see Xia, [0003]-[0005]). Claim 7 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Xia (US 2010/0054028). Regarding claim 1, Xia discloses, in FIG. 1 and in related text, a semiconductor device comprising: a lower word line (130); a magnetic tunnel junction (MTJ) stack (including MTJ 105), wherein a cross section of a first electrode (180) of the stack comprises a hexagonal profile (see Xia, [0003]-[0005]). Claims 1-3 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 MTJ 810), wherein a cross section of a bottom electrode (610) of the stack comprises a hexagonal profile (see Huang, [0027], [0031], [0034]). Regarding claim 2, Huang discloses the device of claim 1. Huang discloses the MTJ stack comprises vertically aligned layers of a top electrode (920), a free layer, a tunneling barrier, a reference layer (of MTJ 810) and the bottom electrode (610) (see Huang, FIG. 13, [0031], [0034], [0040]). Regarding claim 3, Huang discloses the device of claim 1. Huang discloses the bottom electrode (610) comprises a side surface comprising a width (W4) at a middle section of the bottom electrode greater than a width (W2) at a lower surface of the bottom electrode, and the width at the middle section of the bottom electrode greater than a width (W3’) at an upper surface of the bottom electrode (see Huang, FIG. 10B, [0031]). Regarding claim 6, Huang discloses the device of claim 1. Huang discloses an 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]). 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 4-5 are rejected under 35 U.S.C. 103 as being unpatentable over Huang in view of Iwayama (US 2010/0200900). Regarding claim 4, Huang discloses the device of claim 1. Huang discloses that a cross section of a top electrode (920) of the stack comprises a polygonal profile (see Huang, FIG. 13, [0040]). Huang does not explicitly disclose a cross section of a top electrode of the stack comprises a hexagonal profile. Iwayama teaches a cross section of a top electrode (21) of the stack comprises a hexagonal or polygonal profile (see Iwayama, FIG. 3, [0071]). Thus Iwayama teaches a cross section of a top electrode of the stack comprises a hexagonal profile. Huang and Iwayama 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 Huang with the features of Iwayama 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 Huang to include a cross section of a top electrode of the stack comprises a hexagonal profile, as taught by Iwayama, because it is simple substitution of one known element for another (hexagonal profile for polygonal profile) to obtain predictable results (as a top electrode) (see MPEP § 2143), and to provide a method to achieve miniaturization of a magnetoresistive element (see Iwayama, [0141]-[0142]). Regarding claim 5, Huang in view of Iwayama teaches the device of claim 4. Iwayama teaches the top electrode (21) comprises a side surface comprising a width (Wa) at a middle section of the top electrode greater than a width (Wb) at a lower surface of the top electrode, and the width at the middle section of the top electrode greater than a width (Wf) at an upper surface of the top electrode (see Huang, FIG. 3, [0071]), with the same analogous prior art and field of endeavor statement and the same motivation as provided for in claim 4. Claims 7-10 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Huang (US 2017 /0294576) in view of Zhou (US 2016/0284761). Regarding claim 7, Huang discloses, in FIGS. 10B and 13 and in related text, a semiconductor device comprising: a magnetic tunnel junction (MTJ) stack (including MTJ 810), wherein a cross section of a first electrode (610) of the MTJ stack comprises a hexagonal profile (see Huang, [0027], [0031], [0034]). Huang does not explicitly disclose a lower word line. Zhou teaches a lower word line (38) (see Zhou, FIG. 1, [0003]). Huang and Zhou 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 Huang with the features of Zhou 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 Huang to include a lower word line, as taught by Zhou, to form an array of memory cells (see Zhou, [0002]). Regarding claim 8, Huang in view of Zhou teaches the device of claim 7. Huang discloses a magnetic tunnel junction (MTJ) stack (including MTJ 81) above and connected to the first electrode (610) (see Huang, FIG. 13, [0034]). Regarding claim 9, Huang in view of Zhou teaches the device of claim 8. Huang discloses the MTJ stack comprises vertically aligned layers of a top electrode (920), a free layer, a tunneling barrier, a reference layer (of MTJ 810) and the bottom electrode (610) (see Huang, FIG. 13, [0031], [0034], [0040]). Regarding claim 10, Huang in view of Zhou teaches the device of claim 7. Huang discloses the first electrode (610) comprises a side surface comprising a width (W4) at a middle section of the first electrode greater than a width (W2) at a lower surface of the first electrode, and the width at the middle section of the first electrode greater than a width (W3’) at an upper surface of the first electrode (see Huang, FIG. 10B, [0031]). Regarding claim 13, Huang in view of Zhou teaches the device of claim 9. Huang discloses 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]). Claims 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Huang in view of Zhou, and further in view of Iwayama (US 2010/0200900). Regarding claim 11, Huang in view of Zhou teaches the device of claim 10. Huang discloses that a cross section of an upper electrode (920) of the stack comprises a polygonal profile (see Huang, FIG. 13, [0040]). Huang does not explicitly disclose a cross section of a second electrode of the stack comprises a hexagonal profile. Iwayama teaches a cross section of an upper electrode (21) of the stack comprises a hexagonal or polygonal profile (see Iwayama, FIG. 3, [0071]). Thus Iwayama teaches a cross section of a second electrode of the stack comprises a hexagonal profile. Huang and Iwayama 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 Huang with the features of Iwayama 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 Huang to include a cross section of a second electrode of the stack comprises a hexagonal profile, as taught by Iwayama, because it is simple substitution of one known element for another (hexagonal profile for polygonal profile) to obtain predictable results (as a top electrode) (see MPEP § 2143), and to provide a method to achieve miniaturization of a magnetoresistive element (see Iwayama, [0141]-[0142]). Regarding claim 12, Huang in view of Zhou and further in view of Iwayama teaches the device of claim 11. Iwayama teaches the second electrode (21) comprises a side surface comprising a width (Wa) at a middle section of the top electrode greater than a width (Wb) at a lower surface of the second electrode, and the width at the middle section of the top electrode greater than a width (Wf) at an upper surface of the second electrode (see Huang, FIG. 3, [0071]), with the same analogous prior art and field of endeavor statement and the same motivation as provided for in claim 10. 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
Jan 11, 2026
Non-Final Rejection — §102, §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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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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