Prosecution Insights
Last updated: October 27, 2026
Application No. 18/559,491

METHOD FOR PROTECTING REACTIVE MATERIALS WITH ATOMICALLY THIN FILM

Non-Final OA §103§112
Filed
Nov 07, 2023
Priority
May 07, 2021 — provisional 63/185,407 +1 more
Examiner
STEVENSON, ANDRE C
Art Unit
2899
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Columbia University
OA Round
3 (Non-Final)
90%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 90% — above average
90%
Career Allowance Rate
791 granted / 883 resolved
+21.6% vs TC avg
Moderate +7% lift
Without
With
+7.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
30 currently pending
Career history
921
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
78.2%
+38.2% vs TC avg
§102
12.8%
-27.2% vs TC avg
§112
2.4%
-37.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 883 resolved cases

Office Action

§103 §112
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 of an RCE filed on 09/09/2026 has been entered. Specification The specification has not been checked to the extent necessary to determine the presence of all possible minor errors. Applicant’s cooperation is requested in correcting any errors of which applicant may become aware in the specification. 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. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims #58, 60-64, 66, 68-73, 75, 78-81 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. With respect to claim #58, the term "about" is a relative term which renders the claim indefinite; it is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. “About” is defined as " almost or nearly used to indicate that a number, amount, time, etc., is not exact or certain” (see Merriam Webster online dictionary). This language is indefinite as the specification does not describe how much the value can deviate from about 8 A in order to be considered “about” 8 A. The term “about” modifies a target, and implicitly requires boundaries at some maximum value above the target and at some minimum value below the target beyond which one is not “about” the target any more. Neither the claims, nor the specification, defines these boundaries. Thus, it is unclear whether one must be within some small percentage of deviation of the target (such as 0.01 %, 0.1 %, 1 %, 2 %, 5 %, 10 %, or some other percentage) or within a certain number of units of the target (in this case, the target is about 8 A) and specifically which of these possible values defines the boundaries. If one were to poll 100 people having ordinary skill in the art, there would be many different responses for the boundaries. Thus, determining whether one is infringing the limitation is subjective, rather than objective, and thus the claim is unclear. Therefore, the claim is rejected as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention. 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. The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) #58, 60, 61, 63, 72, 73, 78 are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as shown in the rejection of claim #58 above and in view of Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa". Cullen shows, with respect to claim #58, a method of forming a multi-layer structure comprising: providing a substrate (fig. #1, item 155) having a low surface energy surface (paragraph 0025, 0033-0034); depositing a protection layer (fig. #1, item 110) on at least a portion of the low surface energy surface (paragraph 0020, 0033-0034), wherein the protection layer is atomically thin and/or atomically smooth depositing one or more thin film materials on the protection layer to provide one or more layers of thin film materials (paragraph 0028): and detaching the multi-layer structure from the substrate (paragraph 0033-0034); wherein the multi-layer structure comprises the protection layer (fig. #1, item 110) and the one or more layers (fig. #1, item 125, 130, 140) of thin film materials (paragraph 0034). Cullen substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen fails to show, with respect to claim #58 a method comprising forming comprising wherein the low surface energy surface comprises a low surface energy coating or modification disposed on at least a portion of the substrate, the low surface energy surface coating or modification comprising one or more monolayers of fluorine atoms or fluorinated molecules and protection layer is atomically thin in a range of 3 A to 2 nm and/or atomically smooth having an average roughness of less than about 8 A, wherein the protection layer comprises one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2), or a combination thereof. Ogawa teaches, with respect to claim #58, a method of forming comprising wherein the low surface energy surface comprises a low surface energy coating or modification disposed on at least a portion of the substrate, the low surface energy surface coating or modification comprising one or more monolayers of fluorine atoms or fluorinated molecules (column #24, line 22-46) and protection layer is atomically thin in a range of 3 A to 2 nm (column #26, line 21-26; column #29, line 56-60) and/or atomically smooth having an average roughness of less than about 8 A, wherein the protection layer comprises one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2) (column #26, line 65-68; column #27, line 1-12), or a combination thereof. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention, with respect to claim #58, to modify the invention of Cullen with the modification of the invention of Ogawa, which teaches, forming comprising wherein the low surface energy surface comprises a low surface energy coating or modification disposed on at least a portion of the substrate, the low surface energy surface coating or modification comprising one or more monolayers of fluorine atoms or fluorinated molecules and protection layer is atomically thin in a range of 3 A to 2 nm and/or atomically smooth having an average roughness of less than about 8 A, wherein the protection layer comprises one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2), or a combination thereof , to incorporate a structural condition that would provide an ordered, defect-free film that yields enhanced advantages for various electronics conditions, as taught by Ogawa. Cullen shows, with respect to claim #60, a method wherein the method further comprises, prior to step (iv), depositing a capping layer (fig. #1, item 150) on the one or more layers of thin film materials (paragraph 0008, 0021, 0033). Cullen shows, with respect to claim #61, a method wherein the method further comprises, prior to step (iv), providing a delamination promoting layer (fig. #1, item 145) in contact with the capping (fig. #1, item 150) (paragraph 0033). Cullen shows, with respect to claim #63, a method wherein the low surface energy surface (fig. #1, item 155) has a surface energy (polyethylene ≈ 30-36 mJ/m2) of less than about 50 mJ/m2 (paragraph 0025, 0033). Cullen shows, with respect to claim #69, a method wherein the one or more thin film materials are selected from the group consisting of a photosensitive material, a photoemissive material, a photoactive material, an air-sensitive material, an oxygen sensitive material, and a material sensitive to an exposing environment, or a combination thereof (Photoinitiator; paragraph 0022). Cullen shows, with respect to claim #72, a method wherein step (ii) comprises epitaxially growing the protection layer on the substrate in-situ, or transferring the protection layer from a source layer (Photoinitiator; paragraph 0021). Cullen shows, with respect to claim #73, a method wherein the source layer is silicon carbide (SiC),a metal thin film of copper (Cu) or gold (Au), or a polymeric thin film (paragraph 0004) of thermal release tape (paragraph 0022, 0029). Cullen substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen fails to show, with respect to claim #78 a method wherein the protection layer is atomically thin in a range of 3A to 2 nm. Ogawa teaches, with respect to claim #78, a method wherein the protection layer is atomically thin in a range of 3A to 2 nm. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention, with respect to claim #78, to modify the invention of Cullen with the modification of the invention of Ogawa, which teaches, wherein the protection layer is atomically thin in a range of 3A to 2 nm, to incorporate a structural condition that would provide an ordered, defect-free film that yields enhanced advantages for various electronics conditions, as taught by Ogawa. /// Claim #62 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" as shown in the rejection of claim #61 above and in further view of Williams et al., (U.S. Pub. No. 2021/0284887), hereinafter referred to as "Williams". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #61 above. Cullen as modified by Ogawa fails to show, with respect to claim #62, a method wherein the delamination promoting layer comprises a stressed metal film or a tape. Williams teaches, with respect to claim #62, a method wherein the delamination promoting layer comprises a stressed metal film or a tape (paragraph 0051, 0215). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #62, to modified the invention of Cullen as modified Ogawa, with the invention of Williams, which teaches, a method wherein the delamination promoting layer comprises a stressed metal film or a tape, to incorporate a structural condition that would provide a mechanical reinforcement layer or intermediate barrier layer with additional mechanical strength enabling the article to be self-supporting and not very fragile, even when the molding substrate is removed, as taught by Williams. // Claim #64 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" as shown in the rejection of claim #58 above and in view of Rabnawaz et al., (U.S. Pub. No. 2021/0253901), hereinafter referred to as "Rabnawaz". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen as modified by Ogawa, fails to show, with respect to claim #64, a method wherein the low surface energy surface has a water contact angle of greater than 1200. Rabnawaz teaches, with respect to claim #64, a method wherein the low surface energy surface has a water contact angle of greater than 1200 (paragraph 0019, 0051). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #64, to modified the invention of Cullen as modified by Ogawa, with the invention of Rabnawaz, which teaches, a method wherein the low surface energy surface has a water contact angle of greater than 1200, to incorporate a structural condition that promotes the omniphobic polymeric micelles to structurally re-orient themselves, such that the hydrophilic portion that generally fills the pores of the porous substrate, as taught by Rabnawaz. /// Claim #66 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" as shown in the rejection of claim #58 above and in view of Sieber et al., (U.S. Pub. No. 2019/0189898), hereinafter referred to as "Sieber". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen as modified by Ogawa, fails to show, with respect to claim #66, a method wherein the low surface energy surface comprises an atomically smooth surface having a roughness of less than 1 monolayer of deviation from the mean line. Sieber teaches, with respect to claim #66, a method wherein the low surface energy surface comprises an atomically smooth surface having a roughness of less than 1 monolayer of deviation from the mean line (paragraph 0206). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #66, to modified the invention of Cullen as modified by Ogawa, with the invention of Sieber, which teaches, a method wherein the low surface energy surface comprises an atomically smooth surface having a roughness of less than 1 monolayer of deviation from the mean line to incorporate a structural condition that would provide a condition for preparing hydrophobic surfaces with low water permeability, as taught by Sieber. //// Claim #68 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa", as shown in the rejection of claim #58 above and in further view of Koloski et al., (U.S. Pat. No. 6,608,129), hereinafter referred to as "Koloski". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen as modified by Ogawa, fails to show, with respect to claim #68, a method wherein the transition metal dichalcogenide is molybdenum (Mo) or tungsten(W) combined with sulfur(S) selenium(Se), or tellurium (Te). Koloski teaches, with respect to claim #68, a method wherein the transition metal dichalcogenide is molybdenum (Mo) or tungsten(W) combined with sulfur(S) selenium(Se), or tellurium (Te) (column #16, line 35-52; column #36, line 24-64). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #68, to modified the invention of Cullen as modified by Ogawa, with the invention of Koloski, which teaches, a method wherein the transition metal dichalcogenide is molybdenum (Mo) or tungsten(W) combined with sulfur(S) selenium(Se), or tellurium (Te), to incorporate a structural condition such as inorganic molecules which can be polymerized into macromolecular networks or which can be treated so that the inorganic molecules interact with the polymer matrix's functionality, as taught by Koloski. ///// Claim #70 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" and Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa", as shown in the rejection of claim #69 above and in view of GASTON et al., (U.S. Pub. No. 2017/0201205), hereinafter referred to as "Gaston" Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #69 above. Cullen as modified by Ogawa, fails to show, with respect to claim #70, a method wherein the one or more photoemissive, photoactive, photosensitive, or air-sensitive materials are selected from the group consisting of Ag, Mg, Cs3Sb. gallium arsenide (GaAs), an alkali antimonide, indium gallium arsenide (InGaAs), cesium telluride (CsTe), and cesium iodide (Csl), or a combination thereof. Gaston teaches, with respect to claim #70, a method wherein the one or more photoemissive, photoactive, photosensitive, or air-sensitive materials are selected from the group consisting of Ag, Mg, Cs3Sb. gallium arsenide (GaAs), an alkali antimonide, indium gallium arsenide (InGaAs), cesium telluride (CsTe), and cesium iodide (Csl), or a combination thereof, (paragraph 0027). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #70, to modified the invention of Cullen as modified by Ogawa, with the invention of Gaston, which teaches, a method wherein the one or more photoemissive, photoactive, photosensitive, or air-sensitive materials are selected from the group consisting of Ag, Mg, Cs3Sb. gallium arsenide (GaAs), an alkali antimonide, indium gallium arsenide (InGaAs), cesium telluride (CsTe), and cesium iodide (Csl), or a combination thereof, to incorporate a structural condition with characteristics that would allow light conversion to electrical energy, as taught by Gaston. ////// Claim #71 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" and GASTON et al., (U.S. Pub. No. 2017/0201205), hereinafter referred to as "Gaston", as shown in the rejection of claim #70 above and in view of Moody et al., (U.S. Pub. No. 2017/0201205), hereinafter referred to as "Gaston". Cullen as modified by Ogawa and Gaston, substantially shows the claimed invention as shown in the rejection of claim #70 above. Cullen as modified by Ogawa and Gaston fails to show, with respect to claim #71, a method wherein the alkali antimonide is of the formula KxNayRbwCszSb wherein each of x, y, w, and z is independently 0, 1, 2, or 3, provided that x+y+w+z is 3. Moody teaches, with respect to claim #71, a method wherein the alkali antimonide is of the formula KxNayRbwCszSb wherein each of x, y, w, and z is independently 0, 1, 2, or 3, provided that x+y+w+z is 3 (paragraph 0013-0015, 0039). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #71, to modified the invention of Cullen as modified by Ogawa and Gaston, with the invention of Moody, which teaches, a method wherein the alkali antimonide is of the formula KxNayRbwCszSb wherein each of x, y, w, and z is independently 0, 1, 2, or 3, provided that x+y+w+z is 3, to incorporate a structural condition with characteristics that would allow light conversion to electrical energy, as taught by Moody. /////// Claim #76, 77 are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" and in further view of Liu et al., (U.S. Pub. No. 2018/0348639), hereinafter referred to as "Liu". Cullen shows, with respect to claim #76, a multi-layer structure comprising; a protection layer (fig. #1, item 110) and one more layers of one or more thin film materials (fig. #1, item 125, 1220, 130, 145)(paragraph 0033-0034); wherein the protection layer is atomically thin and/or atomically smooth in ta local surface (paragraph 0028). Cullen substantially shows the claimed invention as shown in the rejection of claim #76 above. Cullen fails to show, with respect to claim #76 a multi-layer structure deposited directly on a substrate having a low surface energy surface that includes one or more monolayers of fluorine atoms or fluorinated molecules, the protection layer comprising one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2), or a combination thereof wherein the protection layer is atomically thin in a range of 3 A to 2 nm and/or atomically smooth having an average roughness of less than about 8 A in a local surface area as observed by visual inspection. Ogawa teaches, with respect to claim #76, a multi-layer structure deposited directly on a substrate having a low surface energy surface that includes one or more monolayers of fluorine atoms or fluorinated molecules (column #24, line 22-46), the protection layer comprising one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2) (column #26, line 65-68; column #27, line 1-12), or a combination thereof wherein the protection layer is atomically thin in a range of 3 A to 2 nm (column #26, line 21-26; column #29, line 56-60) and/or atomically smooth having an average roughness of less than about 8 A in a local surface area as observed by visual inspection. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention, with respect to claim #76, to modify the invention of Cullen with the modification of the invention of Ogawa, which teaches, a multi-layer structure deposited directly on a substrate having a low surface energy surface that includes one or more monolayers of fluorine atoms or fluorinated molecules, the protection layer comprising one or more materials selected from the group consisting of graphene, graphene oxide, hexagonal boron nitride (hBN), transition metal dichalcogenides, and silica (SiO2), or a combination thereof wherein the protection layer is atomically thin in a range of 3 A to 2 nm and/or atomically smooth having an average roughness of less than about 8 A in a local surface area as observed by visual inspection, to incorporate a structural condition that would provide an ordered, defect-free film that yields enhanced advantages for various electronics conditions, as taught by Ogawa. Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #76 above. Cullen as modified by Ogawa, fails to show, with respect to claim #76, a structure wherein the area is observed by visual inspection, optical microscope, AFM, electron microscope, or any combination thereof. Liu teaches, with respect to claim #76, a structure wherein the area is observed by visual inspection, optical microscope, AFM, electron microscope, or any combination thereof (paragraph 0124). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #76, to modified the invention of Cullen as modified by Ogawa, with the invention of Liu, which teaches, a structure wherein the area is observed by visual inspection, optical microscope, AFM, electron microscope, or any combination thereof, to verify the mechanical stability of the template, as taught by Liu. Cullen shows, with respect to claim #77, a structure further comprising a capping layer (fig. #1, item 150) in contact with the one or more layers of one or more thin film materials (paragraph 0008, 0021, 0033). //// Claim(s) #79 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa", as shown in the rejection of claim #58 above and in further view of Adib et al., (U.S. Pat. No. 11,331,692), hereinafter referred to as "Adib". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen as modified by Ogawa, fails to show, with respect to claim #79 a method wherein the protection layer is atomically smooth having an average roughness of less than about 8 A. Adib teaches, with respect to claim #79, a method wherein the protection layer is atomically smooth having an average roughness of less than about 8 A (column #15, line 22-28). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention, with respect to claim #79, to modify the invention of Cullen as modified by Ogawa, with the modification of the invention of Adib, which teaches, wherein the protection layer is atomically smooth having an average roughness of less than about 8 A , to incorporate a structural condition that would provide an ordered, defect-free film that yields enhanced advantages for various electronics conditions, as taught by Adib. /// Claim #80, 81 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" as shown in the rejection of claim #58 above and in further view of Hou et al., (U.S. Pat. No. 10,276,399), hereinafter referred to as "Hou". Cullen as modified by Ogawa, substantially shows the claimed invention as shown in the rejection of claim #58 above. Cullen as modified by Ogawa fails to show, with respect to claim #80, a method wherein depositing the protection layer further comprises epitaxially growing the protection layer on the substrate in-situ by physical vapor deposition or molecular beam epitaxy. Hou teaches, with respect to claim #80, a method wherein depositing the protection layer further comprises epitaxially growing the protection layer on the substrate in-situ by physical vapor deposition or molecular beam epitaxy (column #9, line 32-47). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #80, to modified the invention of Cullen as modified Ogawa, with the invention of Hou, which teaches, a method wherein depositing the protection layer further comprises epitaxially growing the protection layer on the substrate in-situ by physical vapor deposition or molecular beam epitaxy, to incorporate a structural condition that would provide a mechanical reinforcement layer or intermediate barrier layer with additional mechanical strength enabling the article to be self-supporting and not very fragile, even when the molding substrate is removed, as taught by Hou. Cullen as modified by Ogawa fails to show, with respect to claim #81, a method wherein depositing the one or more thin film materials further comprises epitaxially growing in-situ the one or more layers of thin film materials by physical vapor deposition or molecular beam epitaxy. Hou teaches, with respect to claim #81, a method wherein depositing the one or more thin film materials further comprises epitaxially growing in-situ the one or more layers of thin film materials by physical vapor deposition or molecular beam epitaxy (column #9, line 32-47). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #81, to modified the invention of Cullen as modified Ogawa, with the invention of Hou, which teaches, a method wherein depositing the one or more thin film materials further comprises epitaxially growing in-situ the one or more layers of thin film materials by physical vapor deposition or molecular beam epitaxy, to incorporate a structural condition that would provide a mechanical reinforcement layer or intermediate barrier layer with additional mechanical strength enabling the article to be self-supporting and not very fragile, even when the molding substrate is removed, as taught by Hou. ////// Claim #75 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cullen et al., (U.S. Pub. No, 2020/0223180), hereinafter referred to as "Cullen" as modified by Ogawa et al., (U.S. Pat. No. 5,437,894), hereinafter referred to as "Ogawa" and Hou et al., (U.S. Pat. No. 10,276,399), hereinafter referred to as "Hou", as shown in the rejection of claim #80 above and in further view of Sieber et al., (U.S. Pub. No. 2019/0189898), hereinafter referred to as "Sieber". Cullen as modified by Ogawa and Hou, substantially shows the claimed invention as shown in the rejection of claim #80 above. Cullen as modified by Ogawa and Hou, fails to show, with respect to claim #75, a method wherein the physical vapor deposition comprises sputter deposition. Sieber teaches, with respect to claim #75, a method wherein the physical vapor deposition comprises sputter deposition (paragraph 0206). It would have been obvious to one having ordinary skill in the art at the time the invention was made, with respect to claim #75, to modified the invention of Cullen as modified by Ogawa and Hou, with the invention of Sieber, which teaches, a method wherein the physical vapor deposition comprises sputter deposition, to incorporate a structural condition that would provide a mechanical reinforcement layer or intermediate barrier layer with additional mechanical strength enabling the article to be self-supporting and not very fragile, even when the molding substrate is removed, as taught by Sieber. EXAMINATION NOTE The rejections above rely on the references for all the teachings expressed in the text of the references and/or one of ordinary skill in the art would have reasonably understood or implied from the texts of the references. To emphasize certain aspects of the prior art, only specific portions of the texts have been pointed out. Each reference as a whole should be reviewed in responding to the rejection, since other sections of the same reference and/or various combinations of the cited references may be relied on in future rejections in view of amendments. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Andre’ Stevenson whose telephone number is (571) 272 1683 (Email Address, Andre.Stevenson@USPTO.GOV). The examiner can normally be reached on Monday through Friday from 7:30 am to 4:30 pm. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Zandra Smith can be reached on 571-272 2429. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Andre’ Stevenson Sr./ Art Unit 2899 10/07/2026 /Brent A. Fairbanks/Supervisory Patent Examiner, Art Unit 2899
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Prosecution Timeline

Show 1 earlier event
Jan 12, 2026
Non-Final Rejection mailed — §103, §112
Apr 13, 2026
Response Filed
May 11, 2026
Final Rejection mailed — §103, §112
Aug 11, 2026
Response after Non-Final Action
Sep 09, 2026
Response after Non-Final Action
Oct 02, 2026
Request for Continued Examination
Oct 05, 2026
Response after Non-Final Action
Oct 13, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12772585
HERMETIC PACKAGE DEVICE AND DEVICE MODULE
3y 1m to grant Granted Oct 20, 2026
Patent 12772822
CONTACT OVER ACTIVE GATE STRUCTURES WITH ETCH STOP LAYERS FOR ADVANCED INTEGRATED CIRCUIT STRUCTURE FABRICATION
2y 3m to grant Granted Oct 20, 2026
Patent 12765338
MOLECULAR LAYER DEPOSITION CARBON MASKS FOR DIRECT SELECTIVE DEPOSITION OF SILICON-CONTAINING MATERIALS
4y 0m to grant Granted Oct 13, 2026
Patent 12765168
Light-Emitting Device, Display Apparatus, Electronic Device, Light-Emitting Apparatus, Lighting Device
2y 6m to grant Granted Oct 13, 2026
Patent 12757406
MEMORY STRUCTURE AND METHOD OF FORMING THE SAME
4y 4m to grant Granted Oct 06, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

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Prosecution Projections

3-4
Expected OA Rounds
90%
Grant Probability
97%
With Interview (+7.2%)
2y 3m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 883 resolved cases by this examiner. Grant probability derived from career allowance rate.

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