DETAILED ACTION
Election/Restrictions
Applicant’s election without traverse of Species A1.2 relating to Figs. 12A and 12B (claims 1-3, 10-12, 15-19, and 21-25) in the reply filed on 07/17/2026 is acknowledged.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 10/20/2024 and 09/12/2025 have been considered by the examiner.
Drawings
The drawings are objected to because Fig. 9A has the arrow representing the reference layer in the incorrect location. Currently, the reference layer is drawn next to the “Lattice-matched Oxide” layer (903); however, it should be next to the “Tetragonal Heusler Layer with Optional SAF Structure” layer (901).
Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance.
Claim Rejections - 35 USC § 102
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 –
(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.
Claim(s) 1 and 23 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Sukegawa et al. (US Pub. 2013/0221461).
Regarding independent claim 1, Sukegawa teaches a magnetoresistive random-access memory cell (Fig. 3; para. 0056, 0101), comprising:
a first magnetic layer (2) having a first lattice constant (para. 0056);
a second magnetic layer (4) having a second lattice constant (para. 0056);
a tunnel barrier (3) between the first and second magnetic layers (para. 0056), wherein the tunnel barrier includes at least one oxide layer (para. 0052) with an oxide layer lattice constant, wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants (para. 0057-0058).
Regarding independent claim 23, Sukegawa teaches method of forming a magnetoresistive random-access memory cell (Fig. 3; para. 0056+, 0101), comprising:
providing a substrate (para. 0060-0062);
forming a first magnetic layer (2) outward of the substrate, the first magnetic layer having a first lattice constant (0064);
forming a tunnel barrier (3) outward of the first magnetic layer, wherein the tunnel barrier includes at least one oxide layer with an oxide layer lattice constant (para. 0065); and
forming a second magnetic layer (4) outward of the tunnel barrier, the second magnetic layer having a second lattice constant (para. 0066);
wherein the oxide layer is formed such that the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants (para. 0057-0058).
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim(s) 1-3 are rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US Pub. 2022/0165939) and/or unpatentable over Jeong et al. (US Pub. 2022/0165939) in view of Sukegawa et al. (US Pub. 2013/0221461).
Regarding independent claim 1, and claims 2-3, Jeong teaches a teaches a magnetoresistive random-access memory cell (Fig. 9; para. 0054), comprising:
a first magnetic layer (Magnetic Electrode (Heusler)) having a first lattice constant;
a second magnetic layer(Magnetic Electrode) having a second lattice constant;
a tunnel barrier (Tunnel Barrier) between the first and second magnetic layers, wherein the tunnel barrier includes at least one oxide layer (para. 0054) with an oxide layer lattice constant,
a templating layer (Templating Layer), wherein at least one of the magnetic layers comprises a perpendicularly-magnetized Heusler compound (Magnetic Electrode (Heusler) – para. 0054 teaches this layer has its magnetic moment aligned perpendicular to the layer plane) grown on the templating layer (Fig. 9; para. 0030 teaching the Heusler layers to be grown on the templating layer),
wherein the at least one of the magnetic layers that comprises the perpendicularly-magnetized Heusler compound grown on the templating layer comprises a free layer (Fig. 9 – having a “switchable magnetic moment” means the same as “free layer”).
Jeong is silent with respect to wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants, wherein the oxide layer lattice constant has the mismatch smaller than six percent with the at least one of the magnetic layers that comprises the perpendicularly-magnetized Heusler compound grown on the templating layer.
Jeong does teach lattice matching to be desirable – “In some embodiments MgAlO can be used as a tunnel barrier, with its lattice spacing being selected by controlling the Mg—Al composition, thereby resulting in better lattice matching with the Heusler compounds” (para. 0054) – thus, it would have been obvious to one of ordinary skill in the art at the time of filing to optimize the lattice constant of the oxide layer to arrive at the claimed invention for the purpose of better lattice matching (MPEP 2144.05, II).
Sukegawa teaches that lattice mismatch is “preferably 5% or less, more preferably 3% or less” (para. 0057-0058); therefore, it would have been obvious to one of ordinary skill in the art at the time of filing to optimize the mismatch of the oxide layer of Jeong as suggested by Sukgawa to arrive at the claimed invention for the purpose of better lattice matching (MPEP 2144.05, II).
Claim(s) 10, 15, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US Pub. 2022/0165939) (and/or unpatentable over Jeong et al. (US Pub. 2022/0165939) in view of Sukegawa et al. (US Pub. 2013/0221461)) and further in view of Kato et al. (US Pub. 2016/0380185).
Re claim 10, Jeong teaches the at least one oxide layer comprises a first oxide layer; the oxide layer lattice constant comprises a first oxide layer lattice constant (Fig. 9; para. 0054).
Jeong and Sukegawa are silent with respect to wherein the tunnel barrier further includes a second oxide layer with a second oxide layer lattice constant.
Kato teaches wherein the tunnel barrier includes a first oxide layer and a second oxide layer (with their corresponding oxide lattice constants) (para. 0107).
It would have been obvious to one of ordinary skill in the art at the time of filing that the tunnel barrier layer of Jeong could be formed using the bilayer structure taught by Kato as both are known options for providing a tunnel barrier layer. It is considered obvious to select a known material based on its suitability for its intended use (2144.07).
Re claims 15 and 16, Jeong teaches wherein at least one of the first magnetic layer and the second magnetic layer includes a perpendicularly-magnetized Heusler compound (para. 0054).
Kato teaches SrO, BaO, and MgO as possible materials for each layer (para. 0106-0107); therefore, it would have been obvious to one of ordinary skill in the art at the time filing to choose “wherein one of the first oxide layer and the second oxide layer is selected from the group consisting of SrO and BaO and another one of the first oxide layer and the second oxide layer is MgO, wherein…the one of the first oxide layer and the second oxide layer that is selected from the group consisting of SrO and BaO is in direct contact with the at least one of the first magnetic layer and the second magnetic layer that includes the perpendicularly-magnetized Heusler compound” with a reasonable expectation of success.
Claim(s) 17, 24, and 24 are rejected under 35 U.S.C. 103 as being unpatentable over Sukegawa et al. (US Pub. 2013/0221461) in view of Faleev et al. (US Pub. 2023/0320231).
Regarding independent claim 17, Sukegawa teaches a magnetoresistive random-access memory cell (Fig. 3; para. 0056, 0101), comprising:
a first magnetic layer (2) having a first lattice constant (para. 0056);
a second magnetic layer (4) having a second lattice constant (para. 0056);
a tunnel barrier (3) between the first and second magnetic layers (para. 0056), wherein the tunnel barrier includes at least one oxide layer (para. 0052) with an oxide layer lattice constant, wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants (para. 0057-0058).
While Sukegawa is silent with respect to “a magnetoresistive random-access memory array, comprising: a plurality of bit lines and a plurality of complementary bit lines forming a plurality of bit line-complementary bit line pairs; a plurality of word lines intersecting the plurality of bit line pairs at a plurality of cell locations; a plurality of magnetoresistive random-access memory cells located at each of the plurality of cell locations, each of the magnetoresistive random-access memory cells being electrically connected to a corresponding bit line and selectively interconnected to a corresponding one of the complementary bit lines under control of a corresponding one of the word lines”, such features are taught by Faleev (para. 0005).
It would have been obvious to one of ordinary skill in the art at the time of filing to form a memory array as taught by Faleev using the MRAM cell of Sukegawa to arrive at the claimed invention for the purpose of providing a memory array with the improved features of Sukegawa (improved lattice matching, high TMR; para. 0035).
Regarding independent claim 24, Sukegawa teaches a magnetoresistive random-access memory cell (Fig. 3; para. 0056, 0101), comprising:
a first magnetic layer (2) having a first lattice constant (para. 0056);
a second magnetic layer (4) having a second lattice constant (para. 0056);
a tunnel barrier (3) between the first and second magnetic layers (para. 0056), wherein the tunnel barrier includes at least one oxide layer (para. 0052) with an oxide layer lattice constant, wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants (para. 0057-0058).
While Sukegawa is silent with respect to “a hardware description language (HDL) design structure encoded on a machine-readable data storage medium, the HDL design structure comprising elements that when processed in a computer-aided design system generates a machine-executable representation of a magnetoresistive random-access memory cell”, such features are taught by Faleev (para. 008).
It would have been obvious to one of ordinary skill in the art at the time of filing to create the HDL as taught by Faleev for the MRAM cell of Sukegawa for the purpose of being able to digitally model the MRAM cell of Sukegawa to facilitate circuit design.
Regarding independent claim 25, Sukegawa teaches a magnetoresistive random-access memory cell (Fig. 3; para. 0056, 0101), comprising:
a first magnetic layer (2) having a first lattice constant (para. 0056);
a second magnetic layer (4) having a second lattice constant (para. 0056);
a tunnel barrier (3) between the first and second magnetic layers (para. 0056), wherein the tunnel barrier includes at least one oxide layer (para. 0052) with an oxide layer lattice constant, wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants (para. 0057-0058).
While Sukegawa is silent with respect to “a hardware description language (HDL) design structure encoded on a machine-readable data storage medium, the HDL design structure comprising elements that when processed in a computer-aided design system generates a machine-executable representation of a magnetoresistive random-access memory array, wherein the magnetoresistive random-access memory array comprises: a plurality of bit lines and a plurality of complementary bit lines forming a plurality of bit line-complementary bit line pairs; a plurality of word lines intersecting the plurality of bit line pairs at a plurality of cell locations; a plurality of magnetoresistive random-access memory cells located at each of the plurality of cell locations, each of the magnetoresistive random-access memory cells being electrically connected to a corresponding bit line and selectively interconnected to a corresponding one of the complementary bit lines under control of a corresponding one of the word lines”, such features are taught by Faleev (para. 0008, 0005).
It would have been obvious to one of ordinary skill in the art at the time of filing to create the HDL of a memory array as taught by Faleev using the MRAM cell of Sukegawa for the purpose of being able to digitally model an MRAM memory array comprising the MRAM cells of Sukegawa to facilitate circuit design.
Claim(s) 17, 18, and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US Pub. 2022/0165939) (and/or unpatentable over Jeong et al. (US Pub. 2022/0165939) in view of Sukegawa et al. (US Pub. 2013/0221461)) and further in view of Faleev et al. (US Pub. 2023/0320231).
Regarding independent claim 17 and claims 18-19, Jeong teaches a teaches a magnetoresistive random-access memory cell (Fig. 9; para. 0054), comprising:
a first magnetic layer (Magnetic Electrode (Heusler)) having a first lattice constant;
a second magnetic layer(Magnetic Electrode) having a second lattice constant;
a tunnel barrier (Tunnel Barrier) between the first and second magnetic layers, wherein the tunnel barrier includes at least one oxide layer (para. 0054) with an oxide layer lattice constant,
a templating layer (Templating Layer), wherein at least one of the magnetic layers comprises a perpendicularly-magnetized Heusler compound (Magnetic Electrode (Heusler) – para. 0054 teaches this layer has its magnetic moment aligned perpendicular to the layer plane) grown on the templating layer (Fig. 9; para. 0030 teaching the Heusler layers to be grown on the templating layer),
wherein the at least one of the magnetic layers that comprises the perpendicularly-magnetized Heusler compound grown on the templating layer comprises a free layer (Fig. 9 – having a “switchable magnetic moment” means the same as “free layer”).
Jeong is silent with respect to wherein the oxide layer lattice constant has a mismatch smaller than six percent with at least one of the first and second lattice constants, wherein the oxide layer lattice constant has the mismatch smaller than six percent with the at least one of the magnetic layers that comprises the perpendicularly-magnetized Heusler compound grown on the templating layer.
Jeong does teach lattice matching to be desirable – “In some embodiments MgAlO can be used as a tunnel barrier, with its lattice spacing being selected by controlling the Mg—Al composition, thereby resulting in better lattice matching with the Heusler compounds” (para. 0054) – thus, it would have been obvious to one of ordinary skill in the art at the time of filing to optimize the lattice constant of the oxide layer to arrive at the claimed invention for the purpose of better lattice matching (MPEP 2144.05, II).
Sukegawa teaches that lattice mismatch is “preferably 5% or less, more preferably 3% or less” (para. 0057-0058); therefore, it would have been obvious to one of ordinary skill in the art at the time of filing to optimize the mismatch of the oxide layer of Jeong as suggested by Sukgawa to arrive at the claimed invention for the purpose of better lattice matching (MPEP 2144.05, II).
While Jeong and Sukegawa are silent with respect to “a magnetoresistive random-access memory array, comprising: a plurality of bit lines and a plurality of complementary bit lines forming a plurality of bit line-complementary bit line pairs; a plurality of word lines intersecting the plurality of bit line pairs at a plurality of cell locations; a plurality of magnetoresistive random-access memory cells located at each of the plurality of cell locations, each of the magnetoresistive random-access memory cells being electrically connected to a corresponding bit line and selectively interconnected to a corresponding one of the complementary bit lines under control of a corresponding one of the word lines”, such features are taught by Faleev (para. 0005).
It would have been obvious to one of ordinary skill in the art at the time of filing to form a memory array as taught by Faleev using the MRAM cell made obvious by Jeong (and/or Joeng in view of Sukegawa) to arrive at the claimed invention for the purpose of providing a memory array with the improved lattice matching.
Claim(s) 21 is rejected under 35 U.S.C. 103 as being unpatentable over Jeong et al. (US Pub. 2022/0165939) (and/or unpatentable over Jeong et al. (US Pub. 2022/0165939) in view of Sukegawa et al. (US Pub. 2013/0221461)) and Faleev et al. (US Pub. 2023/0320231) and further in view of Kato et al. (US Pub. 2016/0380185).
Re claim 21, Jeong teaches the at least one oxide layer comprises a first oxide layer; the oxide layer lattice constant comprises a first oxide layer lattice constant (Fig. 9; para. 0054).
Jeong and Sukegawa are silent with respect to wherein the tunnel barrier further includes a second oxide layer with a second oxide layer lattice constant.
Kato teaches wherein the tunnel barrier includes a first oxide layer and a second oxide layer (with their corresponding oxide lattice constants) (para. 0107).
It would have been obvious to one of ordinary skill in the art at the time of filing that the tunnel barrier layer of Jeong could be formed using the bilayer structure taught by Kato as both are known options for providing a tunnel barrier layer. It is considered obvious to select a known material based on its suitability for its intended use (2144.07).
Allowable Subject Matter
Claims 11, 12, and 22 are 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: there is no teaching, suggestion, or motivation from the prior art of record, nor does the prior art of record otherwise make obvious the limitations of “…wherein the first magnetic layer and the second magnetic layer each include a perpendicularly-magnetized Heusler compound, one of which is a free layer and another of which is a fixed layer…” (emphasis added), in combination with the other limitations.
Conclusion
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/MOLLY K REIDA/Examiner, Art Unit 2899
