Prosecution Insights
Last updated: July 17, 2026
Application No. 18/370,021

TUNGSTEN CMP COMPOSITION INCLUDING A SULFUR CONTAINING ANIONIC SURFACTANT

Non-Final OA §103§112
Filed
Sep 19, 2023
Priority
Sep 22, 2022 — provisional 63/409,079
Examiner
PARVINI, PEGAH
Art Unit
1731
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Cmc Materials LLC
OA Round
3 (Non-Final)
70%
Grant Probability
Favorable
3-4
OA Rounds
2m
Est. Remaining
82%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allowance Rate
730 granted / 1042 resolved
+5.1% vs TC avg
Moderate +12% lift
Without
With
+12.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
26 currently pending
Career history
1068
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
85.7%
+45.7% vs TC avg
§102
3.4%
-36.6% vs TC avg
§112
8.1%
-31.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1042 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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 05/08/2026 has been entered. Claim Rejections - 35 USC § 112 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. Claims 12-13 and 19 are 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. Claims 12, 13, and 19 depend from claim 1; claim 1 has been amended to include a narrower version of the surfactants which would not include any sulfate. However, all said dependent claims claim a number of “sulfate” compounds. 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 § 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. Claim(s) 1-6, 8, 12-14, and 16-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pat. App. Pub. No. 2007/0184661 to Bian et al. (hereinafter Bian) in view of U.S. Pat. App. Pub. No. 2009/0081927 to Grumbine et al. (hereinafter Grumbine) and further in view of U.S. Pat. App. Pub. No. 2003/0022502 to Matsui et al. (hereinafter Matsui). With respect to claim 1, Bian teaches a chemical mechanical polishing composition comprising 0-20 wt% oxidizer, at least 0.001 wt% inhibitor, 1ppm to 4 wt% organic containing ammonium cationic salt formed with quaternary ammonium structure, 1ppm to 4 wt% anionic surfactant having 4-25 carbon atoms, 0-50 wt% abrasive, and the balance water (i.e. liquid carrier), wherein the composition has a pH of less than 7 (Bian, abstract and [0001]). Bain, also, discloses that the composition contains 0.02-2 wt% of a complexing agent such as aspartic acid, glycine, a few others or mixtures thereof (Bain, [0023]), and aspartic acid has been disclosed in the original specification of the present Application under examination as a “tungsten etch inhibitor” (see specification of the present Application under examination, paragraph [0031]). Irrespective of how Bian categorizes a compound such as aspartic acid or glycine, it is one of the same compounds disclosed in the original disclosure of the present Application under examination as “tungsten etch inhibitor”; thus, it is expected of the same compound to have the same effect because substantially similar, if not the exact same compounds, cannot have mutually exclusive characteristics. Bian, additionally, discloses the use of anionic surfactant containing 4-25 carbon atoms, preferably 6-12 carbon atoms wherein some examples of anionic salts include sulfonates (Bian, [0019]); in a preferred embodiment, the reference discloses sodium octane sulfonate as an example of an anionic surfactant (Bain, [0042]); sodium octane sulfonate reads on the claimed formula (i) for the anionic surfactant wherein R is an alkane having 8 carbon atoms. Thus, the claimed “sulfur containing anionic surfactant” as presented in the amended in claim 1, is also met by the reference. Bian, moreover, discloses a pH of less than 7 (Bian, abstract), and further discloses that the pH can be equal to 5 or less (Bian, [0034]). Thus, the reference reads on the claimed limitation of “a pH of less than about 5” as well. Furthermore, Bian discloses that the abrasive is preferably a colloidal abrasive of a metal oxide such as silica or SiO2 which can be a modified form of a metal oxide (Bian, [0027]) such as polymer-coated inorganic oxide particles. Although Bian recognizes the use of modified forms of metal oxides, the reference does not expressly and/or literally disclose the use of “cationic” abrasive particles or particles which are modified to be made cationic or positively charged. It is noted the modified version of abrasive particles of the reference are not limited to “polymer-coated” inorganic oxide particles because the “polymer-coated” version is disclosed as an example. Grumbine, directed to a chemical-mechanical polishing composition comprising a liquid carrier and abrasive particles, discloses the reference is directed to a composition, and method, which would allow for the removal rates of various layers to be adjusted or tuned (Grumbine, [0005]), and thoroughly discloses the importance of CMP compositions (Grumbine, abstract, [0002]-[0005]). Grumbine discloses colloidal silica as the preferred abrasive (Grumbine, [0015]) having been treated on the surface with a silane such as aminosilane (Grumbine, [0011] and [0019]) which would result in increasing the zeta potential of silica from zero, to a positive charge after being treated with the silane (Grumbine, [0024]). The present Application under examination, also, discloses cationic silica particles have been used in the CMP of the present Application under examination, and wherein such particles have been treated with an aminosilane compound (see specification of the present Application under examination, paragraphs [0012]-[0013]). Therefore, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Bian with the teachings of Grumbine in order to utilize not just modified inorganic metal oxide particles as abrasive as that taught by Bian, but to utilize metal oxide particles, such as colloidal silica which is disclosed as the preferred one in Bian, being treated with aminosilane as that taught by Grumbine motivated by the fac that not only the two references are directed to the field of chemical mechanical polishing and the fact that the primary reference teaches the use of modified colloidal silica, but that teaching of Grumbine is, in fact, an evidence of the fact that aminosilane surface treated colloidal silica has been known in the art to result in abrasives having positive zeta potential of about 5-50 mV (Grumbine, [0024]) and the fact that according to Grumbine, their polishing composition results in improved polishing compositions (Grumbine, [0005]). According to the disclosure of both Bian and Grumbine, every component of the polishing compositions are dispersed in water, which reads on the claimed “liquid carrier”. Thus, the combination of Bian in view of Grumbine renders the use of “cationic abrasive particles dispersed in a liquid carrier” obvious. In addition, Bian teaches the use of oxidizers such as nitrates and iron salts (Bian, [0031]) and according to the original disclosure of the present Application under examination, compounds such as iron nitrates, iron sulfates, or iron halides are considered “iron-containing accelerator”. However, although Bian is open to the use of nitrates and iron salts, the reference does not expressly and/or literally disclose the use of an iron salt such as iron nitrate. Matsui, directed to chemical mechanical polishing slurry, discloses a compound such as iron nitrate is recognized as an oxidizer in CMP (Matsui, abstract, [0254]). It is emphasized that Bian discloses the use of oxidizers such as nitrates and iron salts. Therefore, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Bian in view of Grumbine in order to utilize a compound such as iron nitrate, as that taught by Matsui, as the oxidizer in Bian motivated by the fact that Bian recognizes the use of nitrates, and salts of iron as oxidizers, and thus, when the primary reference teaches the use of not only nitrates, but also iron salts as oxidizer, it would be well within the scope of a skilled artisan, prior to the effective filing date of the claimed invention, to have utilized an iron salt oxidizer such as iron nitrate, as that taught by Matsui in light of the fact that it has been recognized as an oxidizer in the field of CMP as that taught by Matsui. Thus, the combination of references renders the claimed “an iron-containing accelerator” obvious as well. It is important to note that irrespective of the category under which the iron nitrate is disclosed in the combination of references, it is one of the very same compounds disclosed in the original disclosure of the present Application under examination as an “iron-containing accelerator”, and substantially similar, if not the same compounds, cannot have mutually exclusive characteristics. With respect to claim 2, as detailed out above, the combination of references renders the claim obvious; this is, in particular, because colloidal silica is disclosed as the preferred abrasive (Bian, [0027] and Grumbine, [0015]) which according to the combination of references, as detailed out above, is rendered obvious to be cationic. With respect to claim 3, as detailed out above, the combination of references renders the presence of aminosilane as a treating agent for colloidal silica obvious; Grumbine teaches treating at least a portion of the surface of colloidal silica with aminosilane (Grumbine, [0010], [0022]). With respect to claim 4, the combination of references, in particular, the combination of Bian in view of Grumbine teaches the use of colloidal silica having positive zeta potential, wherein the zeta potential is from about 5 mV to about 50 mV (Grumbine, [0024]). Thus, the combination of reference teaches an overlapping ranges of zeta potential with what is claimed instantly. MPEP 2144.05 states “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists.” In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). With respect to claim 5, the combination of references renders the claim obvious; this is, in particular, because Bian, as the primary reference, teaches the use of 0-50 wt% of abrasive particles, preferably 0.1-40 wt% (Bian, abstract, [0028]). MPEP 2144.05 states “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists.” In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). With respect to claim 6, the combination of references renders the claim obvious; this is because the combination of Bian in view of Grumbine and further in view of Matsui, in particular, the combination of Bian in view of Matsui teaches iron nitrate, which is an iron-containing catalyst, and Bain, additionally, teaches pH adjusting agents such as phthalic acid, oxalic acid, malonic acid, and a few more which may be used alone or in a mixture (Bian, [0034]). Thus, the two components of iron-containing accelerator, i.e. the soluble iron-containing catalyst and the stabilizer, are taught by the combination of references. This is because according to the original disclosure of the present Application under examination, ferric nitrate is considered an iron-containing catalyst (see specification of the present Application under examination, page 6, paragraphs [0020]-[0021]). With respect to claim 8, the combination of references renders the claim obvious; this is, in particular, because, as noted above under the rejection of claim 1, the combination of reference, in particular, Bian discloses that the composition contains 0.02-2 wt% of a complexing agent such as aspartic acid (Bain, [0023]), and aspartic acid has been disclosed in the original specification of the present Application under examination as a “tungsten etch inhibitor” (see specification of the present Application under examination, paragraph [0031]). Irrespective of how Bian categorizes a compound such as aspartic acid, it is one of the same compounds disclosed in the original disclosure of the present Application under examination as “tungsten etch inhibitor”; thus, it is expected of the same compound to have the same effect because substantially similar, if not the exact same compounds, cannot have mutually exclusive characteristics. With respect to claims 12 and 13, the combination of references is seen to render the claims obvious; this is, in particular, because Bian teaches the use of anionic surfactant such as sodium octane sulfonate (Bian, [0019]-[0020], [0042]). With respect to claim 14, the combination of references renders the claim obvious; this is, in particular, because Bian teaches the use of 1ppm to 4wt% of anionic surfactant, preferably an amount of 10 ppm to 2 wt% (Bian, abstract, [0020]). MPEP 2144.05 states “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists.” In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). With respect to claim 16, the combination of references renders the claim obvious; this is, in particular, because Bian teaches the use of compounds such as glycine in an amount of 0.02-2 wt% (Bain, [0023]), and aspartic acid has been disclosed in the original specification of the present Application under examination as a “tungsten etch inhibitor” (see specification of the present Application under examination, paragraph [0031]). A concentration of about 0.02 wt% corresponds to about 200 ppm. With respect to claim 17, the combination of references renders the claim obvious because Bian, as the primary reference, discloses a pH of less than 7, preferably a pH of equal to or less than 5 (Bian, abstract, [0034]). With respect to claim 18, the combination of references renders the claim obvious because Bian, as the primary reference, not only discloses the use of oxidizers, but that a combination of oxidizers may be used and among the oxidizers, the reference discloses hydrogen peroxide as well (Bian, [0031]). With respect to claim 19, the combination of references renders the claim obvious; this is, in particular, because Bian discloses the use of sodium octane sulfonate as the anionic surfactant in an amount of about 1ppm to 4 wt%, preferably in a concentration of 10ppm to about 2 wt% (Bian, abstract, [0019]-[0020], [0042]), and wherein Bian, also, discloses the use of glycine in a concentration of about 0.02-2 wt% (Bian, [0023]). As detailed out above, under the rejection of claim 1 to which claim 19 depends from, irrespective of under what category of compounds the glycine of Bian is disclosed, it is one of the same compounds as that disclosed in the original disclosure of the present Application under examination, as a tungsten etch inhibitor. Substantially the similar, if not the same compounds, cannot have mutually exclusive characteristics. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bian in view of Grumbine in view of Matsui as applied to claim 1 above, and further in view of U.S. Pat. App. No. 2021/0301178 to Hains et al. (hereinafter Hains). The combination of Bian in view of Grumbine in view of Matsui discloses a chemical mechanical polishing composition comprising water as the liquid carrier, cationic abrasive particles dispersed in the liquid carrier, iron nitrate which would read on “an iron-containing accelerator”, glycine and aspartic acid which would read on the claimed “tungsten etch inhibitor”, sodium octane sulfonate as a sulfur containing anionic surfactant which would read on the claimed structure of formula (i), and a pH of equal to or less than 5, as all detailed out above under the rejection of amended claim 1. Although the combination of references renders the claimed “tungsten etch inhibitor” obvious and although the disclosed pH is acidic, said combination does not expressly and/or literally disclose the compound(s) reading on the tungsten etch inhibitor is/are “positively charged at the pH of the composition”. Hains, directed to chemical mechanical polishing, discloses the use of tungsten etch inhibitors such as polylysine (Hains, [0046]). Hains, also, discloses their polishing composition comprises positively charged colloidal silica, iron-containing accelerator with a stabilizer, in an acidic pH of 5 or less dispersed in water as a liquid carrier, and a few other components (Hains, [0010]-[0012], [0041], [0044]-[0049], [0053]-[0057], [0060]-[0063]). It is noted that according to the original disclosure of the present Application under examination, a compound such as polylysine is a cationic polymer, i.e. positively charged (see specification of the present Application under examination, page 9, paragraph [0031]). Thus, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Bian in view of Grumbine in view of Matsui in order to incorporate the use of a tungsten etch inhibitor such as polylysine, as that taught by Hains, in the chemical mechanical polishing composition of the combination of Bian in view of Grumbine in view of Matsui, motivated by the fact that such an incorporation is considered substitution of known materials for the same purpose because not only Hains discloses polylysine as a tungsten etch inhibitor, but also, said reference discloses compounds such as polygylcine as tungsten etch inhibitor (Hains, [0053] and [0056]), and Bian, as the primary reference, discloses glycine as a component used in their polishing composition (Bian, [0023]). Bian, additionally, discloses that the use of multi-carboxylic acids, carboxylic acids, aminocarboxylic acids, and mixtures thereof is known in said reference (Bian, [0023]). Thus, Bian is open to the use of polyamino acids. Thus, the combination of Bian in view of Grumbine in view of Matsui and further in view of Hains renders the use of a tungsten etch inhibitor which is positively charged at a pH of the composition obvious. Claim(s) 1-4, 6-14, 17-18, and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pat. App. Pub. No. 2021/0301178 to Hains et al. (hereinafter Hains) in view of U.S. Pat. App. Pub. No. 2007/0184661 to Bian et al. (hereinafter Bian). With respect to claim 1, Hains discloses a chemical mechanical polishing composition wherein the polishing composition comprises an iron-containing accelerator including a stabilizer, a tungsten etch inhibitor, liquid carrier, and positively charged colloidal silica as abrasive particles, having a pH of about 5 or less (Hains, abstract, [0010]-[0012], [0041], [0044]-[0048], [0053], [0056], and [0060]). Hains discloses that their polishing composition may be used to polishing substantially any substrate such as those containing at least one metal including tungsten and at least one dielectric material such as silicon oxide which may be carbon doped (Hains, [0002] and [0063]). The use of polishing composition on semiconductor substates has been known (Hains, [0001]). Hains does not expressly and/or literally disclose the use of a sulfur containing anionic surfactant meeting the limitation of formula (i) as amended into claim 1. Bian, directed to chemical mechanical polishing comprising water as a liquid carrier, colloidal silica such as modified version thereof as abrasive particles, components such as glycine or aspartic acid which read on the claimed “tungsten etch inhibitor”, oxidizers such as iron salts, and in general nitrates, and a pH of equal to 5 or less (Bian, abstract, [0001], [0023]-[0024], [0027]-[0034]), discloses the use of sulfur containing anionic surfactants having 6-12 carbon atoms such as sodium octane sulfonate (Bian, [0019]-[0020], [0042]) which has 8 carbons. Bian discloses that such anionic surfactants act in combination with an ammonium salt to accelerate the removal rate of carbon-doped oxides (Bian, [0019]). Thus, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Hains in order to incorporate the sulfur containing anionic surfactant of Bian such as those having 6-12 carbon atoms such as an octane sulfonate, motivated by the fact that not only both references are directed to the same field of art and endeavor of chemical mechanical polishing composition containing a number of similar components, but also the fact that both are used in polishing a substrate containing carbon-doped oxide. Thus, it is reasonable to envision that the use of a sulfur containing anionic surfactant of Bian would improve the polishing result of Hains. With respect to claim 2, Hains discloses their polishing composition comprises abrasive particles such as positively charged colloidal silica (Hains, [0012]). With respect to claim 3, Hains discloses the colloidal silica is treated with an aminosilane to product colloidal silica having a positive charge (Hains, [0060]). When treated, inevitably, the colloidal silica either include the aminosilane or the aminosilane would be on the surface of colloidal silica. With respect to claim 4, Hains discloses the positively charged colloidal silica have a charge of “at least” 10 mV (Hains, [0012]). MPEP 2144.05 states “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists.” In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). With respect to claim 6, Hains discloses the iron-containing accelerator comprises a catalyst and stabilizer such as phosphoric acid (Hains, [0044]-[0048]). With respect to claim 7, Hains discloses a number of compounds as examples of the tungsten etch inhibitor such as cationic polymers having amino acid such as polyglycine (Hains, [0053]-[0056]). The pH of the composition of Hains is 5 or less, as noted above. With respect to claim 8, is a compound such as lysine, glycine, glutamic acid, and other examples are cationic polymers having amino acid such as polyglycine (Hains, [0053]-[0056]). With respect to claims 12-13, the combination of references renders the claim obvious; this is, in particular, because as detailed out above under the rejection of claim 1, although Hains may not literally disclose the use of sulfur containing anionic surfactant such as sodium octane sulfonate, the incorporation of such as compound, as that taught by Bian, in the polishing composition of Hains is well within the scope of a skilled artisan. This is because Bian, directed to chemical mechanical polishing comprising water as a liquid carrier, colloidal silica such as modified version thereof as abrasive particles, components such as glycine or aspartic acid which read on the claimed “tungsten etch inhibitor”, oxidizers such as iron salts, and in general nitrates, and a pH of equal to 5 or less (Bian, abstract, [0001], [0023]-[0024], [0027]-[0034]), discloses the use of sulfur containing anionic surfactants having 6-12 carbon atoms such as sodium octane sulfonate (Bian, [0019]-[0020], [0042]) which has 8 carbons. Bian discloses that such anionic surfactants act in combination with an ammonium salt to accelerate the removal rate of carbon-doped oxides (Bian, [0019]). Thus, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Hains in order to incorporate the sulfur containing anionic surfactant of Bian such as those having 6-12 carbon atoms such as an octane sulfonate, motivated by the fact that not only both references are directed to the same field of art and endeavor of chemical mechanical polishing composition containing a number of similar components, but also the fact that both are used in polishing a substrate containing carbon-doped oxide. Thus, it is reasonable to envision that the use of a sulfur containing anionic surfactant of Bian would improve the polishing result of Hains. With respect to claim 14, the combination of Hains in view of Bian renders the use of a sulfur containing anionic surfactant obvious as detailed out above under the rejection of claim 1, to which claim 14 depends from. Bain, additionally, discloses the use of a concentration of 1ppm to 4 wt%, preferably 10ppm to 2 wt% of anionic surfactant, which overlaps with the claimed concentration of about 1ppm by weight to about 100 ppm by weight. MPEP 2144.05 states “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists.” In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). With respect to claim 17, Hains discloses a pH of equal to or less than 5 (Hains, [0034]). With respect to claim 18, Hains discloses the use of oxidizing agent such as hydrogen peroxide (Hains, [0050]). With respect to claim 20, Hains discloses a chemical mechanical polishing composition and a method of polishing (Hains, abstract), wherein the polishing composition comprises an iron-containing accelerator including a stabilizer, a tungsten etch inhibitor, liquid carrier, and positively charged colloidal silica as abrasive particles, having a pH of about 5 or less (Hains, [0010]-[0012], [0041], [0044]-[0048], [0053], [0056], and [0060]). Hains, additionally, discloses a polishing method and apparatus, wherein the apparatus comprises a platen, which when in use, is in motion, and there is a polishing pad connected to the platen and moves relative to the surface of the substrate to be polished during the polishing method, to polish the substrate (Hains, [0064]). Hains discloses that their polishing composition may be used to polishing substantially any substrate such as those containing at least one metal including tungsten and at least one dielectric material such as silicon oxide which may be carbon doped (Hains, [0002] and [0063]). The use of polishing composition on semiconductor substates has been known (Hains, [0001]). The production of semiconductor substrates requires certain layers (Hains, [0001]-[0002] and [0063]) which inevitably need to be present in certain pattern and format. Hains does not expressly and/or literally disclose the use of a sulfur containing anionic surfactant meeting the limitation of formula (i) as amended into claim 20. Bian, directed to chemical mechanical polishing comprising water as a liquid carrier, colloidal silica such as modified version thereof as abrasive particles, components such as glycine or aspartic acid which read on the claimed “tungsten etch inhibitor”, oxidizers such as iron salts, and in general nitrates, and a pH of equal to 5 or less (Bian, abstract, [0001], [0023]-[0024], [0027]-[0034]), discloses the use of sulfur containing anionic surfactants having 6-12 carbon atoms such as sodium octane sulfonate (Bian, [0019]-[0020], [0042]) which has 8 carbons. Bian discloses that such anionic surfactants act in combination with an ammonium salt to accelerate the removal rate of carbon-doped oxides (Bian, [0019]). Thus, it would have been obvious to a person having ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified Hains in order to incorporate the sulfur containing anionic surfactant of Bian such as those having 6-12 carbon atoms such as an octane sulfonate, motivated by the fact that not only both references are directed to the same field of art and endeavor of chemical mechanical polishing composition containing a number of similar components, but also the fact that both are used in polishing a substrate containing carbon-doped oxide. Thus, it is reasonable to envision that the use of a sulfur containing anionic surfactant of Bian would improve the polishing result of Hains. Response to Arguments Applicant’s arguments, see Remarks pages 2-8, filed 04/07/2026, with respect to the rejection(s) of claim(s) 1-8 and 12-20 under 35 U.S.C. 103 obviousness have been fully considered and, in view of the amendment made to independent claims 1 and 20, are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, two new ground(s) of rejections are made, one in view of Bian as the primary reference and another one, in view of Hains as the primary reference. As such, the argument made over Fu is hereby moot because said reference is withdrawn from the ground(s) of rejection. The amendment made to independent claims 1 and 20 have come from the limitations of previous claims 9, 10, and 11 without the recitation of “a cyclic group having less than 14 carbon atoms” which was part of the previous claim 9. Due to the deletion of “cyclic group” Fu reference has been withdrawn. Allowable Subject Matter Claim 15 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. The following is a statement of reasons for the indication of allowable subject matter: the prior art do not disclose or suggest the cumulative limitations of claims 1 and 15, with particular attention given to tungsten eth inhibitor comprising polylysine being used in an amount from about 1ppm to about 100 ppm. Bian discloses the use of their complexing agents, such as glycine, which has been taken to read on the claimed “tungsten etch inhibitor” in an amount of about 0.02 wt% (i.e. about 200 ppm) to about 2wt%; thus, the concentration of what reads on the claimed “tungsten etch inhibitor” is more than the claimed upper limit. Hains does not disclose any concentration for the compounds disclosed specifically as “tungsten etch inhibitor”. A combination of Hains in view of Bian was not seen to properly render a concentration for the claimed “tungsten etch inhibitor” obvious due to the lack of a motivation on why to incorporate a concentration of 10 ppb to 4 wt%, as disclosed by Bian, for their complexing agents such as glycine, in the teachings of Hains. The compounds that read on “tungsten etch inhibitor” in Bian are disclosed as “complexing agent” used for the purpose of controlling the discoloration of the polishing solution during aging (Bian, [0023]-[0024]). However, the compounds that are disclosed in Hains as “tungsten etch inhibitor” are disclosed to be used to inhibit the removal of tungsten in the substrate. There is no motivation to one of ordinary skill in the art to have utilized the disclosed concentration of Bian for what would read on the claimed “tungsten etch inhibitor” as the concentration of the disclosed tungsten etch inhibitor of Hains. WO 2019/055160 to Chien et al. (hereinafter Chien) submitted in the IDS filed on 05/08/2026, teach a chemical-mechanical polishing composition comprising abrasive particles, removal rate inhibitor(s), an aqueous carrier (abstract, [0005]). The removal rate inhibitor comprises a polyoxyalkylene functional group in combination with one or more (-SO3-) functional groups and/or sulfate ([0026]). Chien, additionally, teaches the removal rate inhibitor comprises a surfactant comprising a sulfonate functional group or a sulfate functional group, and suitable surfactants comprise a sulfonate functional group including an alpha-olefin sulfonate (AOS), which can be, for example, a linear alpha-olefin such as 1-hexene, 1-octene, 1-decene, and more ([0033]-[0034]). However, as can be seen, Chien teaches sulfur containing anionic surfactant of the formula claimed in claim 20 wherein R is an alkene group, not an alkyl or alkane group. Other suitable surfactant taught by Chien are cyclic ones such as those taught in paragraph [0036]; thus, they do not read on the claimed sulfur containing anionic surfactant either. Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled “Comments on Statement of Reasons for Allowance.” Any inquiry concerning this communication or earlier communications from the examiner should be directed to PEGAH PARVINI whose telephone number is (571)272-2639. The examiner can normally be reached Monday-Friday 8:00-5:00. 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, AMBER ORLANDO can be reached at 571-270-3149. 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. /PEGAH PARVINI/Primary Examiner, Art Unit 1731
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Prosecution Timeline

Sep 19, 2023
Application Filed
Sep 22, 2025
Non-Final Rejection mailed — §103, §112
Dec 19, 2025
Response Filed
Jan 08, 2026
Final Rejection mailed — §103, §112
Apr 07, 2026
Response after Non-Final Action
May 08, 2026
Request for Continued Examination
May 12, 2026
Response after Non-Final Action
Jun 17, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12680395
POLYCRYSTALLINE DIAMOND AND METHODS FOR FABRICATING THE SAME
2y 3m to grant Granted Jul 14, 2026
Patent 12667936
BONDED ABRASIVE ARTICLES AND METHODS OF MANUFACTURE
3y 10m to grant Granted Jun 30, 2026
Patent 12643200
METHOD OF MAKING A COATED ABRASIVE ARTICLE AND COATED ABRASIVE ARTICLE
3y 1m to grant Granted Jun 02, 2026
Patent 12629798
ABRASIVE ARTICLES AND METHOD OF MAKING THE SAME
3y 3m to grant Granted May 19, 2026
Patent 12630438
PROCESS FOR PRODUCING PRECIPITATED CALCIUM CARBONATE IN THE PRESENCE OF NATURAL GROUND CALCIUM CARBONATE
3y 1m to grant Granted May 19, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
70%
Grant Probability
82%
With Interview (+12.2%)
3y 0m (~2m remaining)
Median Time to Grant
High
PTA Risk
Based on 1042 resolved cases by this examiner. Grant probability derived from career allowance rate.

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