Prosecution Insights
Last updated: April 19, 2026
Application No. 18/323,158

MEMORY PROGRAMMING WITHOUT COURSE PROGRAMMING VERIFICATION

Non-Final OA §103§112
Filed
May 24, 2023
Examiner
STORMES, JOSEPH FIDELIS
Art Unit
2825
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Yangtze Memory Technologies Co. Ltd.
OA Round
3 (Non-Final)
89%
Grant Probability
Favorable
3-4
OA Rounds
2y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 89% — above average
89%
Career Allow Rate
8 granted / 9 resolved
+20.9% vs TC avg
Strong +17% interview lift
Without
With
+16.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
32 currently pending
Career history
41
Total Applications
across all art units

Statute-Specific Performance

§103
54.5%
+14.5% vs TC avg
§102
28.9%
-11.1% vs TC avg
§112
16.1%
-23.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 9 resolved cases

Office Action

§103 §112
DETAILED ACTION This action is responsive to: the request for continued examination, the amended claim, and the applicant arguments/remarks made in an amendment filed on January 12, 2026. Claims 1-5, 7-12, 14-18, and 20 are pending. Claims 1, 8, and 15 are independent. 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on January 12, 2026 has been entered. Response to Amendment The amendment filed January 12, 2026 has been entered. Claims 1-5, 7-12, 14-18, and 20 remain pending. Applicant’s amendment to the title has overcome the previous objections to the specification. However, applicant has failed to overcome the objections to Fig. 9 and 10. Applicant’s amendment to Claims fails to overcome the rejections due to indefiniteness under 112(b) and rejections based on 112(a). Drawings The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they do not include the following reference sign(s) mentioned in the description: “Vbl2” and “Vbl3” are referenced in the description of waveforms in Fig. 9. but no waveforms are labeled as such in the drawings. “Vbl4” and “Vbl5” are referenced in the description of waveforms in Fig. 10. but no waveforms are labeled as such in the drawings. 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. 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. Applicant stated in response to non-final rejection that Vbl2-5 do not constitute reference signs, but instead are “placeholders for numerical values for transient voltages.” However, applicant included in Figs. 9 and 10 contain the reference signs “Vpgm1,” “Vpgm2,” and “Vpgm3” and “Vpass1,” “Vpass2,” and “Vpass3” which themselves act as reference signs and placeholders for numerical values for transient voltages. Thus, the argument presented by applicant that these figures comply with 37 CFR 1.84(p)(5) is not persuasive. In that applicant has failed to show that the two qualities are mutually exclusive and furthermore a basis for excluding reference signs for bit line voltages in Figs. 9 and 10. Therefore the objection is maintained. Claim Rejections - 35 USC § 112 – new matter 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 1-5, 7-12, 14-18 and 20 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. Applicant amended Independent Claims 1, 8 and 15 to require: in response to the second memory cells corresponding to a fast programming type applying a first voltage to the bit lines coupled to the second memory cells at a first stage of pulse programming, the first voltage less than the suppression voltage; applying the suppression voltage to the bit lines coupled to the second memory cells at a first portion of a second stage of pulse programming subsequent to the first stage; applying a second voltage to the bit lines coupled to the second memory cells at a second portion of the second stage of pulse programming subsequent to the first portion, the second voltage less than the first voltage; applying the suppression voltage to the bit lines coupled to the second memory cells at a third stage of pulse programming subsequent to the first stage; and applying a programming voltage to word lines coupled to the second memory cells to program the second memory cells to the ith programmed state However, applicant has not pointed out where the amended limitation is supported, nor does there appear to be a written description of the claim limitation a method of applying a first stage where a first voltage less than the suppression voltage is applied, a second stage where a suppression voltage is applied and then in the second stage a second voltage less than the first voltage is applied, and finally, a third stage where only a suppression voltage is applied. The claimed “first stage” seems to correspond to application Figure 9 where the specification describes a voltage Vbl3 which is less than the suppression voltage is applied. And the claimed “second stage” seems to relate to Figure 10 where the specification describes first stage where a suppression voltage is applied and second stage where voltage lower than the suppression voltage is applied. Paragraph 31 of the specification states that Fig. 9 represents “an implementation of the present disclosure” and paragraph 32 states that Fig. 10 represents “another implementation of the present disclosure.” Thus, it can only be concluded that since they are not the same implementation the methods of operation disclosed are performed separately. Therefore, the combination of these two stages in succession is not disclosed in the written description or drawings and is thus rejected on the basis that it represent new matter not previously disclosed. Please refer to the examiner’s markups of Fig. 9 and 10 to illustrate the lack of written description issue further. PNG media_image1.png 701 882 media_image1.png Greyscale PNG media_image2.png 700 892 media_image2.png Greyscale Claim Rejections - 35 USC § 112 – indefiniteness 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 1-5, 7-12, 14-18 and 20 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. MPEP 2173.02(II) instructs examiners, “Definiteness of claim language must be analyzed, not in a vacuum, but in light of: (A) The content of the particular application disclosure; (B) The teachings of the prior art; and (C) The claim interpretation that would be given by one possessing the ordinary level of skill in the pertinent art at the time the invention was made.” The claims are not clear and create confusion with the recitation of the variable “i” that must be great than 1, but is also recited as limiting the number of times “pulse programming” is performed by way of an equation “i-1,” along with later recited limitations on i-1 and n>=i and n-1. The disclosure more clearly aligns the “program state” number (e.g., L1, L2, L3, L4) with the number of times pulse programming is performed (e.g., 1, 2, 3, 4, respectively). Some of the clarity issues in the claims are the use of variables recited in ways that are difficult to follow. Other clarity issues involve using terms that do not express the actual feature, but instead express something else that is caused by the unrecited feature. Other clarity issues appear to be translation issues. Other issues appear to raise issues regarding antecedent basis, such as redundantly recited clauses. The best evidence of the confusion and lack of clarity in the claims, is challenges in apply prior art to the claims where the prior art appears to disclose the same invention as applicant discloses (at least insofar as the claims appear to recite, to the extent their recitations are understood). For this reason, and for compact prosecution purposes, Khakifirooz et al. (US 10109361) is provided in the rejection below because it is the closest prior art and describes an identical invention to that disclosed by applicant. As related to the use of “i” and “i-1” (as well as “n” and “n>=i and “n-1”), independent claims 1, 8, and 15, each recite “perform[ing] programming suppression on first memory cells . . . in a coarse programming process, such that the first memory cells are in a first programmed state.” As used in the claim, this “first programmed state” is different from the claimed “ith programmed state” (as recited in claims 1, 3, and 7 (and similarly, 8, 10, 14 and 15, 17, 20). As indicated in applicant’s originally filed disclosure, the “first programmed state” is not a programmed state, but instead is the “erased state” (e.g., Spec. para. 62: “the first programmed state indicates an L0 programmed state, e.g., an erase state.”). The claim requires certain cells to be “program[] suppress[ed].” Applicant explains in their originally filed disclosure (e.g., Spec. para. 49), “a programming suppression voltage is applied to the bit line coupled to the memory cell to cause it not to be programmed any longer.” In the prior art, for example Khakifirooz et al. (US 10109361), explains similarly, for memory cells that have achieved their target program state, their respective bit lines are connected to a voltage (such as 2-3V) “so that they are inhibited from further programming,” (Khakifirooz col. 7, lines 41-45). In other words, the claimed “programming suppression voltage” is program inhibit voltage applied to the bit line. As indicated in the originally filed disclosure, the invention relates to performing coarse program without verify, which is recited in claim 1, and appears to be illustrated in Figure 7 for example. However, the claims are not clear and create confusion with the recitation of the variable “i” that must be great than 1, but is also recited as limiting the number of times “pulse programming” is performed by way of an equation “i-1.” The disclosure more clearly aligns the “program state” number (e.g., L1, L2, L3, L4) with the number of times pulse programming is performed (e.g., 1, 2, 3, 4, respectively). Use of i and i-1 notation creates further confusion in the dependent claims such as dependent claims 3, 10, and 17, which not only redundantly recites “performing the pulse programming for i-1 times” making it unclear whether this is an additional performance of pulse programming for i-1 times or whether its recitation seeks to limit “the performing the pulse programming for i-1 times,” but also appears to link the programming for i-1 times to its antecedent claim’s “n-1 times” for applying programming pulses by way of a “first” i-1 programming pulse that is one of the “n-1 times.” The boundaries of claim 3 are unclear, and create further confusion in its dependent claim 4 (and 11, and 17). Claim 5 (like 12 and 18) repeats “performing the pulse programming for i-1 times on the second memory cells to program the second memory cells to the ith programmed state comprising performing the pulse programming for i-1 times on the second memory cells to program the second memory cells to the ith programmed state . . . .” In short, this clause simply states the memory is programmed “based on a memory cell type,” but every memory is programmed “based upon” its cell type. The applicant further states that the intended for programming to be based upon the memory cell being classified as fast programming type or slow programming type. This feature does not distinguish the claim because there is no indication in the claim as to how the programming would be different based upon the fast type or slow type. As helpful guidance, in response to this rejection, applicant should first carefully consider Khakifirooz et al (US 10109361) and then attempt to determine patentable differences, if any, applicant’s disclosed Figures 7, 9, and 10. At that point, if patentably differences are found, attempt to redraft claims to express the different method of coarse programming without verification. 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. Claims 1-5, 7-12, 14-18, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Her et al (US 20200202915A1), in view of Masuduzzaman (US 20170125087 A1) and Lin (US 20200234768 A1). Regarding Independent Claim 1, Her teaches a method of programming a memory, through a programming operation having a coarse programming process and a fine programming process, the method comprising: performing programming suppression (paragraph 0095 “program inhibit voltage…is applied”) on first memory cells in the coarse programming process, such that the first memory cells are in a first programmed state (fig. 8: E); and performing pulse programming for i-1 times (Fig. 7B: Vpgmn) on second memory cells to program the second memory cells to an ith programmed state (Fig 8: P1-7) in the coarse programming process, where i is an integer greater than 1, applying a programming voltage (Fig. 7B: Vpgmn) to word lines coupled to the second memory cells to program the second memory cells to the ith programmed state, wherein the coarse programming process does not include programming verification (Fig. 7B). However, Her fails to teach methods of programming fast cells by applying bit line voltages of less magnitude or for a shorter duration than what would be applied to slow cells Masuduzzaman teaches that in response to the second memory cells corresponding to a fast programming type: applying a first voltage (Fig. 20B: vbl_high) to the bit lines coupled to the second memory cells at a first stage of pulse programming, the first voltage less than the suppression voltage (para 61 “the connected bit line being pulled to a state designating program inhibit (e.g., Vdd)”); applying the suppression voltage (para 61 “the connected bit line being pulled to a state designating program inhibit (e.g., Vdd)”) to the bit lines coupled to the second memory cells at a third stage of pulse programming subsequent to the first stage (Fig. 21: program slow memory cells, inhibit fast memory cells) ; Lin teaches that in response to the second memory cells corresponding to a fast programming type: applying the suppression voltage (Fig 20: PE_MAX) to the bit lines coupled to the second memory cells at a first portion (Fig 20: t3b, t5) of a second stage of pulse programming; applying the suppression voltage (Fig 20: PE_MAX) to the bit lines coupled to the second memory cells at a third stage (Fig. 20: pulse_D) of pulse programming subsequent to the second stage (Fig. 20: pulse_C); and When cells are fast and thus might be programmed past the desired threshold voltage its desirable to partially inhibit programming by either applying a lower voltage below the suppression voltage to the bit line. Or to apply an inhibit voltage to the bit line during the programming window. Doing such allows less charge to be captured in the cell and thus prevents the threshold voltage of the cell from being programmed beyond the desired value associated with a certain programming state. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to apply the teachings of Lin and Masuduzzaman to the teachings of Her to produce a method of programming fast cells wherein during a programming pulse being applied to the word line a program suppression pulse is applied for part of the duration of the programming pulse. Or that when programming of fast cells a voltage lower than the program suppression pulse is applied. So as not to provide a greater change in threshold voltage during the programming of a fast cell than desired. Regarding Claim 2, Her, Masuduzzaman, and Lin teach the limitations of Claim 1. Her teaches determining a number n of programmed states in the coarse programming process (Fig. 8: P7, Foggy PGM), where n ≥ i; and applying programming pulses for n-1 times (Fig. 7B: PLn-1) to a page in the memory based on the number n of the programmed states in the coarse programming process, the first memory cells and the second memory cells being memory cells in the page. Regarding Claim 3, Her, Masuduzzaman, and Lin teach the limitations of Claim 2. Her teaches wherein performing the pulse programming (Fig. 7B: Vpgm1-n) for i-1 times on the second memory cells to program the second memory cells to the ith programmed state comprises performing the pulse programming on the second memory cells at first i-1 programming pulses of the n-1 programming pulses to program the second memory cells to the ith programmed state. Regarding Claim 4, Her, Masuduzzaman, and Lin teach the limitations of Claim 3. Her further teaches in response to a number i of programming pulses applied to the page not reaching n-1, performing programming suppression on the second memory cells in a pulse programming process starting from an ith programming pulse (Fig 7B: Vpgm1-n) by applying the suppression voltage (paragraph 0095 “program inhibit voltage…is applied”) to the bit lines coupled to the second memory cells. Regarding Independent Claim 8, Her teaches a memory device (Fig 2: 100) with a memory programmable by a programming operation having coarse programming and fine programming, the memory comprising: an array (Fig 2: 110) and a peripheral circuit (Fig 2: 120, 130, 131), wherein the peripheral circuit is configured to perform the method of programming rejected in Claim 1. Regarding Claim 9-11, Her, Masuduzzaman, and Lin teach the limitations of claim 8. And the method of programming, which the memory is configured to perform, that is recited in these claims are rejected for the same reasons as claims 2-4 respectively. Regarding Independent Claim 15, A system (Fig 2: 100), comprising: one or more memories (Fig 2: 100) programmable by a programming operation having coarse programming and fine programming, the memories comprising: an array (Fig 2: 110); and a peripheral circuit (Fig 2: 120, 130, 131), wherein the peripheral circuit is configured to perform the methods rejected in claims 1 and 8. Regarding Claim 16, Her , Masuduzzaman, and Lin teach the limitations of claim 15. And the method of programming, which the memory is configured to perform, that is recited in this claim is rejected for the same reasons as claims 2 and 9. Regarding claim 17, Her, Masuduzzaman, and Lin teach the limitations of claim 16. And the method of programming, which the memory is configured to perform, that is recited in this claim is rejected for the same reasons as claims 3-4 and 10-11. Regarding Claims 5, 12, and 18, Her, , Masuduzzaman, and Lin recite the limitations of Claims 2, 9, and 17. Her fails to teach different methods of classifying memory cells as either fast or slow memory cells for different fine programming operations based on the cell type. However, Masuduzzaman teaches a method of applying a first voltage to word lines (paragraph 0063) coupled to the memory cells in the page; performing programming verification on the memory cells in the page (Fig 16C: 1002); and classifying the memory cells into a fast programming type and a slow programming type based on a threshold voltage of the memory cells (Fig 16C: 1014, 1016), and wherein performing the pulse programming (paragraph 0101) for i-1 times on the second memory cells to program the second memory cells to the ith programmed state comprises performing the pulse programming for i-1 times on the second memory cells to program the second memory cells to the ith programmed state based on a memory cell type of the second memory cells. It would have been prima facie obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to apply the teachings of Masuduzzaman to the teachings of Her to produce a method of programming 3D memories wherein after a coarse programming process without a verification step the cells are classified as either fast or slow cells before the fine programming process begins. Regarding Claims 7, 14, and 20 Her, Masuduzzaman, and Lin teach the limitations of Claims 5, 12, and 18. Lin further teaches wherein performing the pulse programming for i-1 times on the second memory cells to program the second memory cells to the ith programmed state based on the memory cell type of the second memory cells comprises: in response to the second memory cells corresponding to the slow programming type, applying the second voltage (para 235 “0V”) to the bit lines coupled to the second memory cells, and applying the programming voltage (Fig. 20: Vpgm) to the word lines (Fig. 4C: WLL0-WLL14) coupled to the second memory cells to perform the pulse programming for i-1 times to program the second memory cells to the ith programmed state. Response to Arguments Applicant's arguments filed January 26, 2026 have been fully considered but they are not persuasive. With respect to the objections to Figs. 9 and 10 applicant has refused to amend the drawings with the missing references signs and the argument as to why this amendment has not been made is not persuasive as described in the objection itself. Applicant has claimed that the new matter rejection based on portions of the method of programming described in Fig. 9 and portions of the programming described in Fig. 10 being used together in a single programming process is not proper but has not specifically point to where the support for these limitations is in the written description. Applicant merely points to two separate figures (Figs. 9 and 10), but has not referred to a single figure that contains both methods of programming being used together in sequence in a single fast programming process and only refers vaguely to the description “L1 bit line” as to where support can be found in the specification. However, no paragraphs in the specification were provided where support could be found and no support could be found by the examiner upon searching for the term “L1 bit line” in the description. Though support exists for the fast programming process using “the first voltage less than the suppression voltage” and a separate fast programming process using a “second programming voltage less than the first programming voltage” applied at “a second portion of a second stage.” There is no support for a combination of these two fast programming processes, which is the basis for the lack of written description rejection and is explicitly described in the claims 1, 8 and 15. Many of the original indefiniteness issues still remain. Applicant has yet to explain how their previous amendment clears the up the indefiniteness issues. Applicant has merely changed mathematical symbols “>” or “>=” to words that express the same meaning, which does nothing to reduce the confusion around the use of the variables “i” and “n” to describe various facets of the process in the claim. For this reason and the reasons outlines in the rejection itself in greater detail the rejection is maintained. In response to the rejections under 35 U.S.C. 103 applicant has pointed out that features outlined in Her, Masuduzzaman, and Lin could be more clearly described. The rejection has thus been updated to more clearly display the features of each reference that are used to form the conclusion of obviousness. The rejection is maintained. Finally, applicant asserts that the specific sequence of applying the voltages is the basis of the novelty of this invention and because this should overcome the obviousness of the rejection. However, this sequence is lacking in the written description and is the basis for the 112(a) rejection. And since the first stage and second stage accomplish the same goal of presenting fast cell from getting overprogrammed and are taught in Masuduzzaman and Lin respectively, merely combining them in a sequence does represent obviousness. As the two methods are well understood and interchangeable. And the final stage of the sequence is program suppression, which would follow any programming sequence on a cell that you would no longer wish to program during a pulse programming cycle and is standard practice within the art. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOSEPH FIDELIS STORMES whose telephone number is (571)272-3443. The examiner can normally be reached M-F: 6:30am-4pm CST. 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, Alexander Sofocleous can be reached at 571-272-0635. 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. /JOSEPH FIDELIS STORMES/ Examiner, Art Unit 2825 /ALEXANDER SOFOCLEOUS/Supervisory Patent Examiner, Art Unit 2825
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Prosecution Timeline

May 24, 2023
Application Filed
Mar 29, 2025
Non-Final Rejection — §103, §112
Jul 08, 2025
Response Filed
Aug 27, 2025
Final Rejection — §103, §112
Dec 10, 2025
Response after Non-Final Action
Jan 12, 2026
Request for Continued Examination
Jan 24, 2026
Response after Non-Final Action
Jan 30, 2026
Non-Final Rejection — §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
89%
Grant Probability
99%
With Interview (+16.7%)
2y 4m
Median Time to Grant
High
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