Prosecution Insights
Last updated: April 19, 2026
Application No. 18/680,161

Embedding Security into Ferroelectric FET Array via In-Situ Memory Operation

Non-Final OA §102§103
Filed
May 31, 2024
Examiner
SHAW, PETER C
Art Unit
2493
Tech Center
2400 — Computer Networks
Assignee
The Penn State Research Foundation
OA Round
3 (Non-Final)
76%
Grant Probability
Favorable
3-4
OA Rounds
3y 5m
To Grant
99%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allow Rate
422 granted / 553 resolved
+18.3% vs TC avg
Strong +36% interview lift
Without
With
+35.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
46 currently pending
Career history
599
Total Applications
across all art units

Statute-Specific Performance

§101
11.2%
-28.8% vs TC avg
§103
55.7%
+15.7% vs TC avg
§102
13.9%
-26.1% vs TC avg
§112
12.7%
-27.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 553 resolved cases

Office Action

§102 §103
DETAILED ACTION Claims 1-20 are pending in this 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 . 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 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 1, 3, 5-9, 12 and 14-18 and are rejected under 35 U.S.C. 103 as being unpatentable Nardi et al. (US PGPUB No. 2020/0401534) [hereinafter “Nardi”] in view of Lin et al. (US PGPUB No. 2008/0062802) [hereinafter “Lin”] in further view of Gupta et al. (US PGPUB No. 2023/0291541) [hereinafter “Gupta”]. As per claim 1, Nardi teaches a system for configuring a data structure in a nonvolatile memory module, comprising: a non-transitory memory having instructions stored thereon; a processor configured to execute the instructions to perform an operation on a nonvolatile memory (NVM) module, wherein the NVM module includes at least one memory cell comprising two transistors coupled to each other such that a logic value is stored in a complementary manner ([0040], logical values stored in bits which may be implemented as transistors see [0079]), the operation including: encrypting the at least one memory cell by generating a cipher text (CT) by performing an XOR operation on plain text (PT) stored in the at least one memory cell ([0038], XOR operation performed on plaintext and key), and performing the XOR operation on a corresponding key ([0038], XOR operation performed on plaintext and key); or (Examiner Note: “and/or” is interpreted as “or” thus the following “decrypting” feature is optional) decrypting cipher text (CT) of the at least one memory cell by applying a read voltage pattern to the two transistors, the read voltage pattern being based on a key (Examiner Note: to expedite prosecution, this optional feature if included as a required feature, i.e. changing “and/or” to “and”, could overcome the current rejection). Nardi does not explicitly teach two transistors so as to form complementary threshold voltage states. Lin teaches two transistors so as to form complementary threshold voltage states (Fig. 1 and [0002], describing conventionally how SRAM uses transistors to form complimentary voltage states on two bit lines). At the time of filing, it would have been obvious to one of ordinary skill in the art to combine Nardi with the teachings of Lin, two transistors so as to form complementary threshold voltage states, to implement the properties required of a memory cell. The combination of Nardi and Lin does not explicitly teach the operation as an in-situ operation of encrypting and decrypting (Examiner Note: Examiner’s understanding based on the specification, see [0057], is that “in-situ” means encrypting/decrypting at the memory cell directly – without sending to an external module). Gupta teaches the operation as an in-situ operation of encrypting and decrypting ([0023], client is equipped with an accelerator to perform in-memory operations that include encrypting/decrypting data and encoding/decoding data – also described as “in-situ” see Abstract and [0009]). At the time of filing, it would have been obvious to one of ordinary skill in the art to combine Nardi with the teachings of Lin, the operation as an in-situ operation of encrypting and decrypting, to improve performance be reducing latency associated with external encryption and encoding. As per claim 3, the combination of Nardi, Lin and Gupta teaches the system of claim 1, wherein: the two transistors are field-effect-transistors (Nardi; FETs) ([0105], MOS field-effect transistors). As per claim 5, the combination of Nardi, Lin and Gupta teaches the system of claim 1, wherein: the NVM module includes at least one memory block comprising plural memory cells (Nardi; [0034], memory array in NVM comprising plural memory cells see [0003]). As per claim 6, the combination of Nardi, Lin and Gupta teaches the system of claim 5, wherein: the NVM module includes plural memory blocks, and each memory cell within an individual memory block is associated with a key (Nardi; [0091], associated key for an associated NVM memory module where the associated key is stored in a single or multiple cells – stored interpreted to be a type of association [0092]). As per claim 7, the combination of Nardi, Lin and Gupta teaches the system of claim 5, wherein: the plural memory cells is arranged in an array (Nardi; [0034], arranging NVM as a memory cell array). As per claim 8, the combination of Nardi, Lin and Gupta teaches the system of claim 7, wherein: the plural memory cells is arranged as an AND array, a NAND array, or a NOR array (Nardi; [0034], memory array as NAND OR NOR memory cores each with plural memory cells see [0003]). As per claim 9, the combination of Nardi, Lin and Gupta teaches the system of claim 1, wherein: after the CT, the processor is configured to execute the instructions to generate the PT by sensing current when a signal representative of the key is applied to the at least one memory cell (Nardi; [0045], receiving signal which triggers key retrieval and XOR operation to generate plaintext). As per claim 12, the substance of the claimed invention is identical or substantially similar to that of claim 3. Accordingly, this claim is rejected under the same rationale. As per claim 14, the substance of the claimed invention is identical or substantially similar to that of claim 5. Accordingly, this claim is rejected under the same rationale. As per claim 15, the substance of the claimed invention is identical or substantially similar to that of claim 6. Accordingly, this claim is rejected under the same rationale. As per claim 16, the substance of the claimed invention is identical or substantially similar to that of claim 7. Accordingly, this claim is rejected under the same rationale. As per claim 17, the substance of the claimed invention is identical or substantially similar to that of claim 8. Accordingly, this claim is rejected under the same rationale. As per claim 18, the substance of the claimed invention is identical or substantially similar to that of claim 9. Accordingly, this claim is rejected under the same rationale. Claims 2 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Nardi, Lin and Gupta in view of Tanikawa et al. (US PGPUB No. 2012/0163075) [hereinafter “Tanikawa”]. As per claim 2, the combination of Nardi, Lin and Gupta teaches the system of claim 1. The combination of Nardi, Lin and Gupta does not explicitly teach wherein: the two transistors coupled to each other are two consecutively situated transistors. Tanikawa teaches wherein: the two transistors coupled to each other are two consecutively situated transistors ([0032], implementing serial transistors in memory storage). At the time of filing, it would have been obvious to one of ordinary skill in the art to combine Nardi, Lin and Gupta with the teachings of Tanikawa, wherein: the two transistors coupled to each other are two consecutively situated transistors, to provide a efficient way to store logical values on a NVM memory for other processing including encryption/decryption. As per claim 11, the substance of the claimed invention is identical or substantially similar to that of claim 2. Accordingly, this claim is rejected under the same rationale. Claims 4, 10, 13, 19 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Nardi, Lin and Gupta in view of Weingarten (US PGPUB No. 2011/0246792). As per claim 4, the combination of Nardi, Lin and Gupta teaches the system of claim 3. The combination of Nardi, Lin and Gupta does not explicitly teach decrypting cipher text (CT) of the at least one memory cell by applying a read voltage pattern to the two transistors, the read voltage pattern being based on a key. Weingarten teaches decrypting cipher text (CT) of the at least one memory cell by applying a read voltage pattern to the two transistors, the read voltage pattern being based on a key (Fig. 1 and [0030], decrypting information from a memory cell using a stream generated from a key that have a voltage pattern). At the time of filing, it would have been obvious to one of ordinary skill in the art to combine Nardi, Lin and Gupta with the teachings of Weingarten, decrypting cipher text (CT) of the at least one memory cell by applying a read voltage pattern to the two transistors, the read voltage pattern being based on a key, to provide a secure and efficient way to store logical values on a NVM memory for other processing including encryption/decryption. As per claim 10, the substance of the claimed invention is identical or substantially similar to that of claim 4. Accordingly, this claim is rejected under the same rationale. As per claim 13, the substance of the claimed invention is identical or substantially similar to that of claim 4. Accordingly, this claim is rejected under the same rationale. As per claim 19, the substance of the claimed invention is identical or substantially similar to that of claim 4. Accordingly, this claim is rejected under the same rationale. As per claim 20, the substance of the claimed invention is identical or substantially similar to that of claim 4. Accordingly, this claim is rejected under the same rationale. Response to Arguments Applicant's arguments with respect to the objection to claims 1, 4, 10, 13, 19 and 20 have been fully considered and are persuasive. The objections are withdrawn. Applicant's arguments with respect to the rejection of claims 1-20 claims under 35 U.S.C. 102 and 103 have been fully considered and are persuasive and in light of the new amendments, Examiner has introduced a new prior art reference, Gupta, to teach the new aspect of the claimed invention. To further expedite prosecution, Examiner is open to conducting an interview to discuss other claim amendments to overcome this rejection and/or place this application in condition for allowance. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Chou et al. (US Patent No. 12,504,895), Huang et al. (CN-115630406-A), Huang et al. (CN-120316790-A), Zhao et al. ("In-Situ Encrypted NAND FeFET Array for Secure Storage and Compute-in-Memory," 2023 International Electron Devices Meeting (IEDM), San Francisco, CA, USA, 2023, pp. 1-4, doi: 10.1109/IEDM45741.2023.10413774), Duan et al. ("Securing 3D NAND Without Density Loss via In-Situ Encryption Using a Single Transistor XOR Cell," 2025 IEEE International Electron Devices Meeting (IEDM), San Francisco, CA, USA, 2025, pp. 1-4, doi: 10.1109/IEDM50572.2025.11353898) and Luo et al. ("Novel Ferroelectric Tunnel Fet-Based Computing-In-Memory with In-Situ XOR Cipher-Encrypted and-Type Multiply-Accumulate for Secure Edge AI," 2025 9th IEEE Electron Devices Technology & Manufacturing Conference (EDTM), Hong Kong, Hong Kong, 2025, pp. 1-3, doi: 10.1109/EDTM61175.2025.11041150) all disclose various aspects of the claimed invention including encryption/decryption using FET transistor read patterns. Any inquiry concerning this communication or earlier communications from the examiner should be directed to PETER C SHAW whose telephone number is (571)270-7179. The examiner can normally be reached Max Flex. 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, Carl Colin can be reached at 571-272-3862. 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. /PETER C SHAW/Primary Examiner, Art Unit 2493 April 2, 2026
Read full office action

Prosecution Timeline

May 31, 2024
Application Filed
Aug 29, 2025
Response after Non-Final Action
Sep 18, 2025
Non-Final Rejection — §102, §103
Dec 02, 2025
Response Filed
Feb 19, 2026
Final Rejection — §102, §103
Mar 03, 2026
Examiner Interview Summary
Mar 03, 2026
Applicant Interview (Telephonic)
Mar 03, 2026
Request for Continued Examination
Mar 15, 2026
Response after Non-Final Action
Apr 04, 2026
Non-Final Rejection — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12566852
NEFARIOUS CODE DETECTION USING SEMANTIC UNDERSTANDING
2y 5m to grant Granted Mar 03, 2026
Patent 12547696
WIRELESS BATTERY MANAGEMENT SYSTEM SAFETY CHANNEL COMMUNICATION LAYER PROTOCOL
2y 5m to grant Granted Feb 10, 2026
Patent 12536342
SOC ARCHITECTURE WITH SECURE, SELECTIVE PERIPHERAL ENABLING/DISABLING
2y 5m to grant Granted Jan 27, 2026
Patent 12511438
DYNAMIC PROVISION OF SOFTWARE APPLICATION FEATURES
2y 5m to grant Granted Dec 30, 2025
Patent 12513190
SNAPSHOT FOR ACTIVITY DETECTION AND THREAT ANALYSIS
2y 5m to grant Granted Dec 30, 2025
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
76%
Grant Probability
99%
With Interview (+35.7%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 553 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month