CTNF 18/541,444 CTNF 91297 Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. DETAILED ACTION Election/Restrictions Applicant’s election without traverse of Group I (claims 1-13) in the reply filed on 5/4/26 is acknowledged. Claims 14-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Further, Applicant’s election without traverse of Species A in the reply filed on 5/4/26 is acknowledged. The claim readable on the elected Species is claim 3. Claim 4 is withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election (claims 1-3 and 5-13) was made without traverse in the reply filed on 5/4/26. Abstract 06-13 AIA The abstract of the disclosure is objected to because it is written in legal terminology which is too similar to claim language. In particular, legal phraseology such as the term “comprising”, “said” and “wherein” which are commonly used to define the limitations and scope pf patent claims, should generally be avoided in U.S. patent abstracts because the purpose of the abstract is not to define the patent claims, but to provide the reader with a clear and concise summary. The abstract should use plain language to describe the invention's technical problem, solution, and principal use. The abstract should be in narrative form and generally limited to a single paragraph on a separate sheet within the range of 50 to 150 words in length. The language should be clear and concise and should not repeat information given in the title. It should avoid using phrases which can be implied, such as, “The disclosure concerns,” etc . Correction is required. See MPEP § 608.01(b). Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. Claims 1-3 and 5-13 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Regarding claim 1, the “...the second PCM is compositionally different than the first PCM and has a properties group consisting of at least one of: a higher crystallization temperature than the first PCM, a longer crystallization time than the first PCM, more easily forms a void than the first PCM, and combinations thereof...” The limitation "more easily forms a void than the first PCM" renders the claim indefinite because it is a relative term that lacks an objective standard for determining the scope of the claim. Specifically, the claim fails to identify: • the conditions under which void formation is evaluated; • the amount or degree of void formation required; • the number of forming or programming cycles used for comparison; • the current, voltage, pulse duration, temperature, or other operating conditions used to determine whether one PCM forms a void "more easily" than another PCM; or • any objective test or measurement by which one of ordinary skill in the art could determine whether a particular second PCM satisfies the recited limitation. As a result, one of ordinary skill in the art would not be able to determine with reasonable certainty whether a given PCM material falls within the scope of the claim. The specification repeatedly refers to the second PCM as having at least one property selected from a group including a PCM that "more easily forms voids" than the first PCM. For example, the specification states: "The second PCM in one or more arrangements has a properties group consisting of at least one of: a higher crystallization temperature (higher Tc) than the first PCM, a longer crystallization time than the first PCM, more easily forms voids (e.g., void forming) than the first PCM, and combinations thereof." The specification further states: "the PCM 252 in second PCM layer 250 easily forms voids ... when subject to multiple formation current pulses." However, the specification does not provide a definition, threshold value, test methodology, or other objective criterion for determining when a PCM "more easily forms a void" than another PCM. Accordingly, the metes and bounds of claim 1 cannot be determined with reasonable certainty, and claim 1 is therefore indefinite under 35 U.S.C. 112(b). Regarding claim 10. the "wherein the first PCM is electrically conductive in the crystalline state and electrically resistive in the amorphous state and the second PCM is an inverse PCM that is electrically resistive in the crystalline state and electrically conductive in the crystalline state." The limitation directed to the second PCM is internally inconsistent because the claim simultaneously characterizes the second PCM as an "inverse PCM" and further recites that the second PCM is both: 1. electrically resistive in the crystalline state; and 2. electrically conductive in the crystalline state. Thus, the claim requires the second PCM to exhibit mutually exclusive electrical properties in the same crystalline state. One of ordinary skill in the art would not be able to determine with reasonable certainty the scope of the claim because it is unclear whether applicant intended the second PCM to be electrically conductive in the amorphous state (consistent with the description of an inverse PCM in the specification) or electrically conductive in the crystalline state as expressly recited. The specification describes an inverse PCM as being electrically resistive in the crystalline state and electrically conductive in the amorphous state. For example, the specification states: "iPCM 152 is electrically conductive in its amorphous state and electrically resistive in its crystalline state." Accordingly, claim 10 is indefinite because the metes and bounds of the claimed second PCM cannot be reasonably determined. For purposes of examination, the examiner interprets claim 10 under the broadest reasonable interpretation as requiring a phase change material layer programmable between amorphous and crystalline states, wherein the amorphous state is relatively electrically resistive and the crystalline state is relatively electrically conductive. This interpretation is adopted solely for examination purposes in view of the ambiguity discussed above. Without indicating allowability, applicant may wish to amend claim 10 to recite: "...the second PCM is an inverse PCM that is electrically resistive in the crystalline state and electrically conductive in the amorphous state." if that is the intended claim scope. Regarding claims 2-3 and 5-13, because of their dependency on claim 1, these claims are also objected for the reasons set forth above with respect to claim 1. Claim Rejections - 35 USC § 102 07-07-aia AIA 07-07 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – 07-08-aia AIA (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale or otherwise available to the public before the effective filing date of the claimed invention. 07-12-aia AIA (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. 07-15 AIA Claims 1, 9-10 and 12 are rejec ted under 35 U.S.C . 102(a)(1) as being antici pate d by Phili pp (US 200802 73 378; in the IDS on 2/20/25). Regarding claim 1. Fig 2A of Philipp discloses A memory structure comprising: a first electrode 202 [0062]; a first phase change material (PCM) layer 204a comprising a first PCM [0058], the first PCM layer positioned above the first electrode; a second PCM layer 204b located above the first PCM layer, the second PCM layer comprising a second PCM [0058] wherein the second PCM is compositionally different than the first PCM (Philipp discloses that first phase change material layer 204a and second phase change material layer 204b have different crystallization speeds. [0059]. Philipp further discloses embodiments in which the phase change materials having the different crystallization speeds comprise different phase change material compositions, including doped GeSb and doped GeSbTe, doped SbTe and doped GeSbTe. [0061]. Accordingly, Philipp teaches first and second phase change materials that are compositionally different) and has a properties group consisting of at least one of: a higher crystallization temperature than the first PCM, a longer crystallization time than the first PCM, more easily forms a void than the first PCM, and combinations thereof (Philipp discloses an embodiment in which first phase change material layer 204a includes a phase change material having a faster crystallization speed than second phase change material layer 204b. [0059]. Thus, Philipp discloses a second phase change material having a longer crystallization time than a first phase change material); a barrier layer 210 positioned in between the first PCM layer and the second PCM layer [0066] wherein the barrier layer inhibits intermixing of the first PCM layer and the second PCM layer (Philipp discloses that diffusion barriers 210 prevent diffusion between phase change material layers 204. [0081]. Accordingly, Philipp teaches a barrier layer that inhibits intermixing of the first phase change material layer and the second phase change material layer); and a second electrode 206 [0063] positioned above the second PCM layer. Regarding claim 9. Philipp discloses The memory structure of claim 1, wherein the first PCM material comprises a GeSbTe alloy (GST) [0061], a SbTe alloy, an InSe alloy, Cr2Ge2Te6 (CrGeT), Si—Sb—Te (silicon-antimony-tellurium) alloys, Ga—Sb—Te (gallium-antimony-tellurium) alloys, Ge—Bi—Te (germanium-bismuth-tellurium) alloys, In—Se (indium-tellurium) alloys, As—Sb—Te (arsenic-antimony-tellurium) alloys, Ag—In—Sb—Te (silver-indium-antimony-tellurium) alloys, Ge—In—Sb—Te alloys, Ge—Sb alloys [0061], Sb—Te alloys, Si—Sb alloys, or any combination thereof. Regarding claim 10. Philipp discloses The memory structure of claim 1, wherein the first PCM is electrically conductive in the crystalline state and electrically resistive in the amorphous state and the second PCM is an inverse PCM that is electrically resistive in the crystalline state and electrically conductive in the crystalline state (Philipp discloses selectively programming first phase change material layer 204a and second phase change material layer 204b into amorphous and crystalline states. Specifically, Philipp teaches an embodiment in which second phase change material layer 204b is crystalline and first phase change material layer 204a is amorphous. Philipp further teaches an embodiment in which first phase change material layer 204a is crystalline and second phase change material layer 204b is amorphous. Philipp additionally teaches embodiments in which both phase change material layers are crystalline and embodiments in which both phase change material layers are amorphous. [0065]). Regarding claim 12. Philipp discloses The memory structure of claim 1, further comprising the barrier layer being positioned in a first positional group consisting of at least one of: over, adjacent to, or in contact with at least a portion of the first PCM layer and the barrier layer is further positioned in a second positional group consisting of: below, adjacent to, or in contact with at least a portion of the second PCM layer (Philipp discloses diffusion barrier 210 positioned between first phase change material layer 204a and second phase change material layer 204b. Specifically, Philipp teaches that "Diffusion barrier 210 is in contact with first phase change material layer 204a" and that "Second phase change material layer 204b is in contact with diffusion barrier 210." [0066]. Accordingly, diffusion barrier 210 is in contact with at least a portion of the first phase change material layer 204a and is further in contact with at least a portion of the second phase change material layer 204b. Because "in contact with" is expressly recited within each of the claimed positional groups and expressly disclosed by Philipp, Philipp teaches the positional limitations of claim 12) . Claim Rejections - 35 USC § 103 07-20-aia AIA 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. 07-21-aia AIA Claim s 2-3 are rejected under 35 U.S.C. 103 as being unpatentable over by Philipp (US 20080273378; in the IDS on 2/20/25) in view of in view of Philip (US 20210305503) . Regarding claim 2. Philipp discloses The memory structure of claim 1. But Philipp does not expressly disclose further comprising an electrically insulating region formed above the barrier layer in the second PCM layer. However, Philip discloses a phase change material layer 180 having an amorphous phase region 185 formed therein. Specifically, Philip teaches that a region of phase change material layer 180 can be converted to amorphous phase region 185. [0074]. Philip further discloses that amorphous phase region 185 exhibits a higher resistivity than the surrounding crystalline phase of phase change material layer 180 and that read current bypasses amorphous phase region 185. [0075]. Thus, Philip teaches a localized high-resistance region formed within a phase change material layer. [0074]-[0075]. Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the second phase change material layer 204b of Philipp to include the localized amorphous phase region taught by Philip because Philip teaches that such a region provides a higher-resistance region within the phase change material and permits current to bypass the region, thereby improving resistance-state behavior and memory operation. [0075]. The resulting device would include a localized high-resistance region corresponding to the claimed electrically insulating region formed within the second PCM layer 204b of Philipp and therefore above barrier layer 210. Regarding claim 3. Philipp in view of Philip discloses The memory structure of claim 2, wherein the electrically insulating region is dome shaped (Philip expressly discloses that amorphous phase region 185 may be "a projection having a hemispherical or dome shape" within phase change material layer 180. [0074]. Therefore, Philip discloses the dome-shaped electrically insulating region recited in claim 3) . 07-21-aia AIA Claim s 5-8 are rejected under 35 U.S.C. 103 as being unpatentable over by Philipp (US 20080273378; in the IDS on 2/20/25) in view of in view of Lee (US 20240107778) . Regarding claim 5. Philipp discloses The memory structure of claim 1, Philipp further discloses the barrier layer is at least one of a group consisting of: electrically conductive [0067], semiconductive, and combinations thereof. But Philipp does not expressly disclose wherein the barrier layer is the same thickness or thinner than the thickness of the first PCM layer. However, Lee discloses a phase-change memory structure including phase-change layers 121, 122, and 123 separated by barrier layers 130. Lee further teaches that barrier layers 130 may have a thickness of about 1 nm to about 10 nm. [0077]. Lee additionally teaches that phase-change layers may have thicknesses of about 10 nm to about 30 nm. [0084]. Thus, Lee teaches barrier layers that are thinner than adjacent phase-change layers. [0077], [0084]. Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the barrier layer 210 of Philipp with the thickness relationship taught by Lee because Lee teaches such dimensions for barrier layers disposed between phase-change material layers in a multi-layer phase-change memory structure. Regarding claim 6. Philipp in view of Lee discloses The memory structure of claim 1, wherein the first PCM layer is thinner than the second PCM layer (As discussed above, Lee expressly discloses that barrier layers 130 may have a thickness of about 1 nm to about 10 nm. [0077]). Regarding claim 7. Philipp in view of Lee discloses The memory structure of claim 6, wherein the first PCM layer is 15 nm thick or less (Lee discloses that phase-change layer 121 may have a thickness of about 10 nm to about 30 nm. [0084]. Thus, Lee teaches a phase-change layer having a thickness greater than 10 nm. [0084]). Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to utilize the PCM layer thickness taught by Lee in the memory device of Philipp because Lee teaches such dimensions for phase-change layers in a multi-layer phase-change memory structure. Regarding claim 8. Philipp in view of Lee discloses The memory structure of claim 7, wherein the second PCM layer has a thickness greater than 30 nm (Lee expressly discloses that barrier layers 130 may have a thickness of about 1 nm to about 10 nm. [0077]) . 07-21-aia AIA Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over by Philipp (US 20080273378; in the IDS on 2/20/25) in view of in view of Song (US 20200168792) . Regarding claim 11. Philipp discloses The memory structure of claim 10. But Philipp does not expressly disclose wherein the inverse PCM is Cr2Ge2Te6 (CrGeT). However, Fig 2B of Song discloses a memory device including phase-change layer 230, tunnel barrier 260, and selector layer 240. Song further teaches that selector layer 240 comprises a transition-metal-containing phase change material and specifically teaches CrGeTe and Cr ₂ Ge ₂ Te ₆ as suitable materials for selector layer 240. [0093]. Song additionally discloses that tunnel barrier 260 is disposed between phase-change layer 230 and selector layer 240 and functions as a barrier between the layers. [0101]-[0103]. Thus, Song teaches a stacked memory structure including a barrier layer positioned between a phase-change layer and a CrGeTe-based phase-change material layer. Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to utilize the CrGeTe or Cr ₂ Ge ₂ Te ₆ phase-change material taught by Song as the material of one of the PCM layers of Philipp because Song teaches that such Cr-containing Ge-Te phase-change materials are suitable for use in phase-change memory devices and provide desirable phase-transition and resistance-switching characteristics. [0088]-[0093]. Therefore, the substitution of Song's known CrGeTe-based phase-change material for one of Philipp's known PCM materials would have been a predictable use of a known phase-change material according to its established function in a phase-change memory device . 07-21-aia AIA Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over by Philipp (US 20080273378; in the IDS on 2/20/25) in view of in view of Li (US 20200168792) . Regarding claim 13. Philipp discloses The memory structure of claim 11. But Philipp does not expressly disclose further comprising a protective liner positioned between the first electrode and the first PCM material, the protective liner comprising a resistive non-switching material to shunt the amorphous state and reduce resistive drift of the first PCM layer. However, Li discloses a phase change memory device including bottom electrode 204, conductive oxide liner material 203, and phase change material 202/205, wherein conductive oxide liner material 203 is physically positioned between bottom electrode 204 and phase change material 202/205 (Fig. 2; [0028], [0032], [0049]). Li further teaches that conductive oxide liner material 203 acts as a thermal barrier between the PCM and the bottom electrode. [0032]. Thus, liner material 203 functions as a protective liner and corresponds to the claimed protective liner. Li further discloses that conductive oxide liner material 203 maintains its resistance, acts as a semiconductor having a controllable resistance, and possesses a resistivity selected relative to the resistivity of the phase change material. Specifically, Li teaches that the conductive oxide liner material may have a resistivity of about 0.1 to 10 times the crystalline resistivity of the PCM. [0032]. Thus, Li teaches a resistive non-switching material. Additionally, Li discloses that conductive oxide liner material 203 is provided to improve PCM operation and reduce resistance drift associated with the phase change material. Li specifically identifies reduced resistance drift as a benefit of the disclosed liner structures. [0010]-[0012], [0036]. Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate conductive oxide liner material 203 of Li into the phase change memory device of Philipp between the first electrode and the first PCM layer because Li expressly teaches that such a liner improves phase change memory performance and reduces resistance drift. The modification merely applies Li's known liner structure and drift-reduction technique to Philipp's known phase change memory device to obtain the predictable benefit of improved resistance stability and memory operation. Accordingly, the combination of Philipp and Li teaches or suggests a protective liner comprising a resistive non-switching material to shunt the amorphous state and reduce resistive drift of the first PCM layer, the protective liner being positioned between the first electrode and the first PCM layer, as recited in claim 13. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Changhyun Yi whose telephone number is (571)270-7799. The examiner can normally be reached Monday-Friday: 8A-4P. 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, Davienne Monbleau can be reached on 571-272-1945. 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. /Changhyun Yi/Primary Examiner, Art Unit 2812 Application/Control Number: 18/541,444 Page 2 Art Unit: 2812 Application/Control Number: 18/541,444 Page 3 Art Unit: 2812
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