Prosecution Insights
Last updated: April 19, 2026
Application No. 18/335,205

MEMORY DEVICE AND METHOD OF MANUFACTURING THE SAME

Non-Final OA §103§112
Filed
Jun 15, 2023
Examiner
REAMES, MATTHEW L
Art Unit
2896
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Kioxia Corporation
OA Round
1 (Non-Final)
77%
Grant Probability
Favorable
1-2
OA Rounds
2y 9m
To Grant
95%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allow Rate
827 granted / 1076 resolved
+8.9% vs TC avg
Strong +18% interview lift
Without
With
+17.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
32 currently pending
Career history
1108
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
40.7%
+0.7% vs TC avg
§102
20.0%
-20.0% vs TC avg
§112
33.8%
-6.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1076 resolved cases

Office Action

§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 claims 1-11 in the reply filed on 12/15/2025 is acknowledged. Claims 12-17 withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected method, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 12/15/2025. 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, a structure with both the silicon nitride over the side surface of the second oxide and the third oxide 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 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 5-6 and 10-11 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. As to claims 5 and 10, claim 1 requires: A memory device comprising: a first ferromagnetic layer; a second ferromagnetic layer; a first insulating layer between the first ferromagnetic layer and the second ferromagnetic layer; a first oxide over a side surface of the first ferromagnetic layer, a side surface of the first insulating layer, and a side surface of the second ferromagnetic layer; a second oxide provided over the first oxide, and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide; and a silicon nitride over a side surface of the second oxide. Claim 7 requires A memory device comprising: a first ferromagnetic layer; a second ferromagnetic layer; a first insulating layer between the first ferromagnetic layer and the second ferromagnetic layer; a first oxide over a side surface of the first ferromagnetic layer, a side surface of the first insulating layer, and a side surface of the second ferromagnetic layer; a second oxide provided over the first oxide, and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide; and a silicon nitride over a side surface of the second oxide, wherein an oxygen concentration of a portion of the first insulating layer facing the second oxide is higher than an oxygen concentration of a central portion of the first insulating layer. With respect to claims 5 and 6, these claims further require a conductor on a side of the first ferromagnetic layer opposite to the first insulating layer along a first direction; an insulator aligned with the conductor along a second direction intersecting the first direction; and a third oxide provided on the insulator and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide. Claim 10 and 11 also require a conductor on a side of the first ferromagnetic layer opposite to the first insulating layer along a first direction; an insulator aligned with the conductor along a second direction intersecting the first direction; and a third oxide provided on the insulator and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide. I. There is no antecedent basis in the specification for “third oxide.” It appears to be drawn to the remnant that remain in figure 9 processing of 42a. Figure 9 is an intermediate process step for making the final device. However, paragraph 71 states: After the second IBE described with reference to FIG.9, a silicon nitride 46 is formed on a surface of the oxide 42 (or, surface opposite to the MTJ element MTJ), as shown in FIG.4. Subsequently, the oxide 42A is removed through etching, and the conductor 33A, the variable resistance material 32A, and the conductor 31A are respectively formed into the upper electrode 33, the variable resistance material 32, and the lower electrode 31. Examples of the etching include reactive ion etching (RIE) and IBE. Thereby, the structure shown in FIG.4 is completed. Thus, in the finished device of claim 1 there is no oxide provided on the insulator. Elements 31-33 do not extend past the outer most portion of the silicon nitride after the etch to singulate memories figure 4 and figure 3. II. Assuming arguendo that there exists a third oxide in the final product of claim 1 and 7. Claims 5 and 10 are not supported applicant does not have support for the third oxide to be a different oxide from the second. Since 42A is only shown as a remaining portion of the second oxide. As the written the second oxide could be and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide and independently the third oxide could be any of a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide which is not supported. Thus, the claim encompasses embodiment where the second oxide is silicon oxide and the third oxide is Magnesium oxide. The specification does not support this since 42a is a portion of 42 (the second oxide) As to claim 6 and 11, I. As to claim 6 and 11, In the same manner it appears that applicant is referring item 42A which in figure 9 is formed on the conductor however paragraph 71 states: After the second IBE described with reference to FIG.9, a silicon nitride 46 is formed on a surface of the oxide 42 (or, surface opposite to the MTJ element MTJ), as shown in FIG.4. Subsequently, the oxide 42A is removed through etching, and the conductor 33A, the variable resistance material 32A, and the conductor 31A are respectively formed into the upper electrode 33, the variable resistance material 32, and the lower electrode 31. Examples of the etching include reactive ion etching (RIE) and IBE. Thereby, the structure shown in FIG.4 is completed. There is no third insulator on the conductor since in the step of forming the nitride the third oxide is removed. Elements 31-33 does not extend past the outer most portion of the silicon nitride after the etch to singulate memories figure 4 and figure 3. II. Assuming arguendo that there exists a third oxide in the final product of claim 1 and 7 . Claims 6 and 11 are not supported applicant does not have support for the third oxide to be a different oxide from the second. Since 42A is only shown as a remaining portion of the second oxide. As the written the second oxide could be and including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide and independently the third oxide could be any of a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide which is not supported. Thus, the claim encompasses embodiment where the second oxide is silicon oxide and the third oxide is Magnesium oxide. The specification does not support this since 42a is a portion of 42 (the second oxide) 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. Claim(s) 1-2, and 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sonoda 20200091411 cited on ids. a. As to claim 1, Sonoda teaches A memory device comprising: a first ferromagnetic layer (figure 3-13 item 55); a second ferromagnetic layer (item 57); a first insulating layer between the first ferromagnetic layer and the second ferromagnetic layer (item 56); a first oxide over a side surface of the first ferromagnetic layer, a side surface of the first insulating layer, and a side surface of the second ferromagnetic layer (item 72 paragraph 47); a second insulator (item 73/74); and a silicon nitride over a side surface of the second oxide (item 78 paragraph 51). Sonoda teaches that 73/74 maybe silicon nitride or silicon oxide paragraph 48. Applicant has shown no unexpected results for having a silicon oxide vs silicon nitride. Thus, it would have been obvious to one of ordinary skill in the art at the time of filing to have formed 73/74 as silicon oxide for the desired passivation and insulation properties and low trap properties of silicon oxide. b. As to claim 2 Sonoda teaches the second oxide maybe 1 nm to 5 nm paragraph 50 but does not explicitly teach 1 nm. Applicant has shown no unexpected results for the thickness at 1 nm. Thus, it would have been obvious to one of ordinary skill in the art at the time of filing to have form the thickness of the second oxide to be 1nm. To optimize the deposition time do be short while still maximizing the insulative properties of the item 73/74. c. As to claim 4, Sonoda teaches wherein the second oxide is positioned on a surface of the first oxide opposite to a surface of the first oxide facing the first ferromagnetic layer, the first insulating layer, and the second ferromagnetic layer (72 formed with two sidewall and one sidewall is adjacent to the 55/57 and the other side wall is adjacent to 73/74 thus 72/73 is formed on the side opposite to the one facing 55/57). Claim(s) 5 and 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sonoda in view of Igarashi 20220085278 cited on ids. As to claims 5 and 6, Sonoda does not teach a conductor on a side surface of the first ferromagnetic layer opposite to the first insulating layer along a first direction, and contacting the first ferromagnetic layer; an insulator aligned with the conductor along a second direction intersecting the first direction and a third oxide provided on the insulator or the conductor the third oxide including a magnesium oxide, an aluminum oxide, a silicon oxide, or an alkaline-earth metal oxide. Igarashi teaches providing a selection element including a conductor 26 an insulator 25 and a portion of the spacer is on the sidewall of the conductor and a side surface of the insulator. Thus, it would have been obvious to one of ordinary skill in the art at the time of filing to include at the base of Sonoda the selection element including to conductor item 26 and insulator 25 and bottom conductor item 124 to provide an integrated selection device for the MTJ to allow access to the memory too allow array integration. It would have been further obvious at the time of filing to provide spacers Sonoda on the sidewalls of the upper conductor and the top side of the insulator to provide passivation and isolation of upper conductor. The third oxide can be considered to be the portion provided below. PNG media_image1.png 333 850 media_image1.png Greyscale There is no requirement that the third oxide and second oxide cannot be part of the same layer. Allowable Subject Matter Claim 3 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. As to claim 3 prior art fails to teach and or suggest wherein the first oxide includes an oxide of at least one element included in at least one of the first ferromagnetic layer, the first insulating layer, and the second ferromagnetic layer. Sonoda teaches the oxide is is a easily oxidizable metal which is part of the electrode not the ferromagnetic layer. Claims 7-9 are allowed. As to claim 7, Hsu 2021/0343930 teach varying the oxygen (paragraph 65 and 87) but does not teach or suggest wherein an oxygen concentration of a portion of the first insulating layer facing the second oxide is higher than an oxygen concentration of a central portion of the first insulating layer. In conjunction with the other elements of claim 7. Claim 10 and 11 would be allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 1st paragraph, set forth in this Office action. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MATTHEW L REAMES whose telephone number is (571)272-2408. The examiner can normally be reached M-Th 6:00 am-4:00 pm EST. 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, William F. Kraig can be reached at 571-272-8660. 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. /MATTHEW L. REAMES/ Primary Examiner Art Unit 2896 /MATTHEW L REAMES/ Primary Examiner, Art Unit 2896
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Prosecution Timeline

Jun 15, 2023
Application Filed
Jan 21, 2026
Non-Final Rejection — §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
77%
Grant Probability
95%
With Interview (+17.8%)
2y 9m
Median Time to Grant
Low
PTA Risk
Based on 1076 resolved cases by this examiner. Grant probability derived from career allow rate.

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