Prosecution Insights
Last updated: October 02, 2026
Application No. 18/486,467

SIP-TYPE ELECTRONIC DEVICE AND METHOD FOR MAKING SUCH A DEVICE

Final Rejection §103
Filed
Oct 13, 2023
Priority
Oct 14, 2022 — FR 22 10616
Examiner
SARKER-NAG, AKHEE
Art Unit
2893
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Commissariat à l'Énergie Atomique et aux Énergies Alternatives
OA Round
2 (Final)
82%
Grant Probability
Favorable
3-4
OA Rounds
5m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 82% — above average
82%
Career Allowance Rate
58 granted / 71 resolved
+13.7% vs TC avg
Moderate +12% lift
Without
With
+12.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
29 currently pending
Career history
103
Total Applications
across all art units

Statute-Specific Performance

§103
65.6%
+25.6% vs TC avg
§102
20.3%
-19.7% vs TC avg
§112
14.0%
-26.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 71 resolved cases

Office Action

§103
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 . Response to Amendment This office Action is in response to Applicant’s amendment filed on June 29, 2026. Claims 7-8, 11-14 have been amended. No new claims have been added. No claims have been canceled. Claims 1-6 remained withdrawn. Currently claims 1-14 are pending. Response to Arguments Applicant's arguments with respect to claims 7, filed on June 29, 2026, have been fully considered but they are not persuasive. The reason is set forth below. Regarding Amended claim 7, Remarks, page 8 stated “'461 application admittedly fails to disclose six of the eight steps recited in original Claim 7, such that the relevance of the '461 application to the present application is not clear.” However, prior art 461 “Yu et al.” is relied upon for the fan-out framework performed on a temporary carrier as Yu et al. discloses the steps of attaching the chip, encapsulating, forming redistribution layer, debonding the carrier, attaching a further substrate and forming interconnect elements by bonding techniques such as direct bonding, hybrid bonding, or the like (Yu et al., ¶ [0032]). The rejection is based on a combination of prior arts 461 “Yu et al.” in view of 881 “Mallik et al.” further in view of 754 “Lin et al.”. One cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., Inc., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Where a rejection of a claim is based on two or more references, a reply that is limited to what a subset of the applied references teaches or fails to teach, or that fails to address the combined teaching of the applied references may be considered to be an argument that attacks the reference(s) individually. Where an applicant’s reply establishes that each of the applied references fails to teach a limitation and addresses the combined teachings and/or suggestions of the applied prior art, the reply as a whole does not attack the references individually as the phrase is used in Keller and reliance on Keller would not be appropriate. This is because "[T]he test for obviousness is what the combined teachings of the references would have suggested to [a PHOSITA]." In re Mouttet, 686 F.3d 1322, 1333, 103 USPQ2d 1219, 1226 (Fed. Cir. 2012); MPEP 2145(IV). Applicant further stated “the '881 application fails to disclose the steps of after bonding the first and second metal layers, detaching the first substrate off the electronic chip and the encapsulation material; after detaching the first substrate, making at least one redistribution layer electrically coupled to the electrical interconnection face of the electronic chip; and after making the at least one redistribution layer, making electrical interconnection elements over the redistribution layer such that the electrical interconnection elements are electrically coupled to the electronic chip by the redistribution layer, as recited in amended Claim 7." and “'754 application fails to disclose the bonding of the first and second metal layers, and thus cannot disclose the step of after bonding the first and second metal layers, detaching the first substrate off the electronic chip and the encapsulation material, as recited in amended Claim 7. Thus, Applicant respectfully submits that one of ordinary skill in the art would clearly not look to any teachings of the '754 application to be combined with those of the '881 application. Thus, no matter how the teachings of the '461, '881, and '754 applications are combined, the combination does not teach or suggest the steps recited in amended Claim 7.” However, 881 “Mallik et al.” discloses affixing, encapsulating, first metal layer, second metal layer, direct bonding, detaching and interconnection coupling in the same order as the claimed limitation order except for the limitation “after making the at least one redistribution layer, making electrical interconnection elements over the redistribution layer such that the electrical interconnection elements are electrically coupled to the electronic chip by the redistribution layer,” which is disclosed by 754 “Lin et al.”. Furthermore, all three references are in the same field of endeavor of semiconductor packaging of encapsulated chips and discloses clear motivation to combine the arts. Furthermore, the selection of any order of performing process steps is prima facie obvious in the absence of new or unexpected results. See Ex parte Rubin, 128 USPQ 440 (Bd. App. 1959) (Prior art reference disclosing a process of making a laminated sheet wherein a base sheet is first coated with a metallic film and thereafter impregnated with a thermosetting material was held to render prima facie obvious claims directed to a process of making a laminated sheet by reversing the order of the prior art process steps.). See also In re Burhans, 154 F.2d 690, 69 USPQ 330 (CCPA 1946) (selection of any order of performing process steps is prima facie obvious in the absence of new or unexpected results); In re Gibson, 39 F.2d 975, 5 USPQ 230 (CCPA 1930) (Selection of any order of mixing ingredients is prima facie obvious.); MPEP2144.04(IV)(C). The applicant has not identified any unexpected results attributed to the recited order. For the stated reasons above a final rejection has been made using Yu, Chen-Hua (US 20220199461 A1) “Yu et al.” in view of Mallik, Debendra (US 20210035881 A1) “Mallik et al.” further in view of Lin, Yaojian (US 20150021754 A1) “Lin et al.”. 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 7-9 and 11-14 are rejected under 35 U.S.C. 103 as being unpatentable over Yu, Chen-Hua (US 20220199461 A1) “Yu et al.” in view of Mallik, Debendra (US 20210035881 A1) “Mallik et al.” further in view of Lin, Yaojian (US 20150021754 A1) “Lin et al.”. Regarding Independent Claim 7, Yu et al. Figs. 5-8 discloses a method for making a SiP-type electronic device (“a semiconductor package” ¶ [0079]), comprising at least: affixing an electronic chip (“one or more integrated passive devices (IPDs) 80 (see FIG. 5)” ¶ [0026]) over a first substrate (“a first carrier substrate 102” ¶ [0027]) such that an electrical interconnection face of the electronic chip 80 is arranged on the side of the first substrate 102; after affixing (Figs. 5-6 shows encapsulant 118 is formed after the IPDs 80 placed on the substrate 102) the electronic chip 80, encapsulating the electronic chip in an encapsulation material (“encapsulant 118 encapsulates…the IPDs 80” ¶ [0033]); However, Yu et al. does not disclose, after encapsulating the electronic chip, making at least one first metal layer over the encapsulation material and the electronic chip; after making the at least one first metal layer, making at least one second metal layer over a second substrate; after making the at least one second metal layer, directly bonding the first and second metal layers against one another; after bonding the first and second metal layers, detaching the first substrate off the electronic chip and the encapsulation material; after detaching the first substrate, making at least one redistribution layer electrically coupled to the electrical interconnection face of the electronic chip; and after making the at least one redistribution layer, making electrical interconnection elements over the redistribution layer such that the electrical interconnection elements are electrically coupled to the electronic chip by the redistribution layer. In the similar field of endeavor of packaged semiconductor devices, Mallik et al. Figs. 2A-2F discloses, after encapsulating the electronic chip (“a mold material 250 covers IC chips 221, 222, and is adjacent to a sidewall of chip substrate 223” ¶ [0025]), making at least one first metal layer over the encapsulation material and the electronic chip (“a back-side bond material 260 is in contact with each chip substrate 223, and is also in contact with mold material 250 within spaces between IC chips 221, 222” ¶ [0027]; 260 is formed after 250); after making the at least one first metal layer (“a back-side bond material 260 is in contact with each chip substrate 223, and is also in contact with mold material 250 within spaces between IC chips 221, 222” ¶ [0027]), making at least one second metal layer 275 (“Bond material 275 may have any of the above compositions (e.g., solder, Cu, Au, SiO.sub.2, polymer) etc.” ¶ [0031]) over a second substrate (“a bulk substrate 270” ¶ [0031]; 270 is formed after 260); after making the at least one second metal layer (Fig. 2F shows the bonding after forming the first and second metal layer 260 and 275), directly bonding the first and second metal layers (“a bond material 275 is bonded to back-side bond material 260” ¶ [0031]) against one another; It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. including the first and second metal layer bonded together of Mallik et al. in order to improve thermal conduction and/or dissipation of heat from the IC chips, the integrated heat spreader offers both mechanical and thermal advantages (Mallik et al. ¶ [0033]). However, Mallik et al. does not disclose, after bonding the first and second metal layers, detaching the first substrate off the electronic chip and the encapsulation material; after detaching the first substrate, making at least one redistribution layer electrically coupled to the electrical interconnection face of the electronic chip; and after making the at least one redistribution layer, making electrical interconnection elements over the redistribution layer such that the electrical interconnection elements are electrically coupled to the electronic chip by the redistribution layer. In the similar field of endeavor of packaged semiconductor devices, Lin et al. Figs. 12a-12f and 18a-18j discloses detaching the first substrate off the electronic chip and the encapsulation material (“In FIG. 12c, carrier 250 and interface layer 252 are removed” ¶ [0085]); after detaching the first substrate (“In FIG. 12c, carrier 250 and interface layer 252 are removed” ¶ [0085]), making at least one redistribution layer electrically coupled to the electrical interconnection face of the electronic chip (“An electrically conductive layer or RDL 264” ¶ [0087]); after making the at least one redistribution layer (“An electrically conductive layer or RDL 264” ¶ [0087]), making electrical interconnection elements (“a build-up interconnect structure 260 is formed over semiconductor die 224 and encapsulant 256” ¶ [0086]) over the redistribution layer 264 such that the electrical interconnection elements are electrically coupled to the electronic chip by the redistribution layer (Fig. 12d shows 224 and 268 are coupled by 264). It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures after bonding the first and second metal layers, of Yu et al. as modified by Mallik et al. by including the steps of making RDL after detaching the first substrate of Lin et al. in order to provide a low resistive interconnect to conductive layer, as well as a barrier to solder diffusion and seed layer for solder wettability (Lin et al. ¶ [0089]). Regarding Claim 8, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 7. However, Yu et al. does not disclose, making the first metal layer includes depositing a first copper layer over the encapsulation material and the electronic chip, and making the second metal layer includes at least depositing a second copper layer over the second substrate. In the similar field of endeavor of packaged semiconductor devices, Mallik et al. Figs. 2A-2F discloses, making the first metal layer includes at least depositing a first copper layer (“bond material 260 comprises a layer of metallization (e.g., Cu, Au, In, Sn, Ag, Bi, or Ni, and alloys thereof)” ¶ [0027]) over the encapsulation material 250 and the electronic chip 223 (“a back-side bond material 260 is in contact with each chip substrate 223, and is also in contact with mold material 250 within spaces between IC chips 221, 222” ¶ [0027]); making the second metal layer 275 includes at least depositing a second copper layer (“Bond material 275 may have any of the above compositions (e.g., solder, Cu, Au, SiO.sub.2, polymer) etc.” ¶ [0031]) over the second substrate (“a bulk substrate 270” ¶ [0031]); directly bonding the first and second metal layers (“a bond material 275 is bonded to back-side bond material 260” ¶ [0031]) against one another; It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. including the first and second metal layer bonded together of Mallik et al. in order to improve thermal conduction and/or dissipation of heat from the IC chips, the integrated heat spreader offers both mechanical and thermal advantages (Mallik et al. ¶ [0033]). Regarding Claim 9, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 8. However, Yu et al. does not disclose, wherein directly bonding the first and second metal layers against one another corresponds to directly bonding the first and second copper layers against one another. In the similar field of endeavor of packaged semiconductor devices, Mallik et al. Figs. 2A-2F discloses, wherein directly bonding the first and second metal layers against one another corresponds to directly bonding the first and second copper layers against one another (“Cu—Cu bonding” ¶ [0030]; “a bond material 275 is bonded to back-side bond material 260” ¶ [0031]). It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. including the first and second metal layer bonded together of Mallik et al. in order to improve thermal conduction and/or dissipation of heat from the IC chips, the integrated heat spreader offers both mechanical and thermal advantages (Mallik et al. ¶ [0033]). Regarding Claim 11, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 7. However, Yu et al. does not disclose, wherein the encapsulation of the electronic chip includes depositing the encapsulation material over the electronic chip, then flattening the encapsulation material. In the similar field of endeavor of packaged semiconductor devices, Mallik et al. Figs. 2A-2F discloses, wherein the encapsulation of the electronic chip includes at least depositing the encapsulation material over the electronic chip, then flattening the encapsulation material (“an overmold planarization process has thinned mold material 250” ¶ [0027]). It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. including the planarization process to obtain thinned mold material of Mallik et al. in order to expose a back side of each of IC chips (Mallik et al. ¶ [0027]). Regarding Claim 12, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 7. Yu et al. further discloses, wherein several electronic chips are simultaneously affixed on the first substrate such that an electrical interconnection face of each of the electronic chips is arranged on the side of the first substrate (“The interconnect structure 100 includes one or more interconnect components 50 (see FIG. 1) and/or one or more integrated passive devices (IPDs) 80 (see FIG. 5). In FIGS. 2 through 8, a first region 101A and a second region 101B are illustrated, and an interconnect structure 100 may be formed in each of the regions 101A and 101B.” ¶ [0026]), and wherein the other steps of the method are collectively implemented for all the electronic chips, and the method further includes, after making the electrical interconnection elements (claim 7 discloses the other steps of the method are collectively implemented for all electronic chips, and further including, after making the electrical interconnection elements), cutting the obtained structure so as to obtain several distinct SiP-type electronic devices each including one or more electronic chip(s) (“A singulation process may be performed to singulate individual interconnect structures 100 such as that shown in FIG. 9.” ¶ [0026]). Regarding Claim 13, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 11. However, Yu et al. does not disclose, wherein, when the electronic chips have different thicknesses, the flattening the encapsulation material is stopped at the electronic chip(s) having the largest thickness. In the similar field of endeavor of packaged semiconductor devices, Lin et al. Figs. 12a-12f discloses wherein, when the electronic chips 224 have different thicknesses, flattening the encapsulation material is stopped at the electronic chip(s) having the largest thickness (Figs. 12f shows encapsulant or molding compound 256 is flatten and stops at the thickest 224). It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. as modified by Mallik et al. in order to remove damage to base material of semiconductor die. Back surface of semiconductor die, having a reduced height with respect to adjacent semiconductor die, remains covered by encapsulant (Lin et al. ¶ [0092]). Regarding Claim 14, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 7. Yu et al. does not disclose, further including, after making the electrical interconnection elements, etching the second substrate forming structures promoting heat exchange with the external environment, and/or wherein the second substrate includes at least one integrated vapor chamber. In the similar field of endeavor of packaged semiconductor devices, Mallik et al. Fig. 4 discloses, further including, after making the electrical interconnection elements (“LTS may be similarly enlisted for subsequently formed SMT solder interconnects of a package substrate” ¶ [0029]), etching the second substrate forming structures (124) promoting heat exchanges with the external environment, and/or wherein the second substrate (116) includes at least one integrated vapor chamber (“etched into bulk substrate 270 with any suitable technique. As shown, channels 410 place a coolant inlet 405 located over IC chip 221 in fluid communication with a coolant outlet 410 located over IC chip 222. Coolant inlet 405 and outlet 410 each open into the opposing side of heat spreader 280. The Multi-chip unit 401 may therefore be fu” ¶ [0036]). It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the interconnect structures of Yu et al. as modified by Mallik et al. and Lin et al. including the planarization process to obtain thinned mold material of Mallik et al. in order to facilitate heat extraction from the multi-chip unit (Mallik et al. ¶ [0036]). Claims 10 is rejected under 35 U.S.C. 103 as being unpatentable over Yu, Chen-Hua (US 20220199461 A1) “Yu et al.” in view of Mallik, Debendra (US 20210035881 A1) “Mallik et al.” further in view of Lin, Yaojian (US 20150021754 A1) “Lin et al.” further in view of Kim, Jin Young (US 20160211221 A1) “Kim et al.” and Enquist; Paul M. (US 20170179029 A1) “Enquist et al.”. Regarding Claim 10, Yu et al. as modified by Mallik et al. and Lin et al. discloses the limitations of claim 8. However, Yu et al. does not disclose, wherein: making the first metal layer further includes depositing a first gold layer over the first copper layer, and making the second metal layer further includes depositing a second gold layer over the second copper layer, and- directly bonding the first and second metal layers against one another corresponds to directly bonding the first and second gold layers against one another. In the similar field of endeavor of packaged semiconductor devices Kim et al. Figs. 10E-10F discloses an upper seed layer 30 may be formed on the top surface of the insulation layer 730. The upper seed layer 30 may, for example, comprise any or all characteristics of the first seed layer 20 and/or the second seed layer 21 discussed herein. For example, the upper seed layer 30 may comprise copper (e.g., a plated copper layer or foil). Also for example, the upper seed layer 30 may comprise one or more layers of any of a variety of metals (e.g., copper, silver, gold, aluminum, tungsten, titanium, nickel, molybdenum, alloys thereof, etc.. It would have been obvious to person having ordinary skill in the art before the effective filling date to modify the process of making the first metal layer further includes depositing a first gold layer over the first copper layer, and the process of making the second metal layer further includes depositing a second gold layer over the second copper layer, and- directly bonding the first and second metal layers against one another corresponds to directly bonding the first and second gold layers against one another of Yu et al. as modified by Mallik et al. and Lin et al. with the seed layer of Kim et al. in order to offer numerous advantages and distinctions from prior low temperature wafer bonding techniques. The metal-to-metal direct bonding is spontaneous and requires no external forces at room temperature. The pressure applied on the metal posts that is required for metal-to-metal bonding is generated by bonding process itself, and not external forces. The metal-to-metal direct bonding described above can be performed under ambient conditions and the following are realized: wafer level or die size bonds, strong metallic Au—Au, Cu—Cu or metal-to-metal bonds formed at room temperature (Enquist et al. ¶ [00118]). Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to AKHEE SARKER-NAG whose telephone number is (703)756-4655. The examiner can normally be reached Monday - Friday 7:15 AM to 5:30 PM. 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, YARA J. GREEN can be reached at (571) 270-3035. 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. /AKHEE SARKER-NAG/Examiner, Art Unit 2893 /YARA B GREEN/ Supervisor Patent Examiner, Art Unit 2893
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Prosecution Timeline

Oct 13, 2023
Application Filed
Feb 27, 2026
Non-Final Rejection mailed — §103
Jun 29, 2026
Response Filed
Sep 14, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
82%
Grant Probability
94%
With Interview (+12.5%)
3y 5m (~5m remaining)
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