Office Action Predictor
Last updated: April 16, 2026
Application No. 18/729,141

MAGNETORESISTIVE ELEMENT AND MAGNETIC MEMORY

Non-Final OA §103
Filed
Jul 15, 2024
Examiner
TECHANE, MUNA A
Art Unit
2827
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Sony Semiconductor Solutions Corporation
OA Round
1 (Non-Final)
93%
Grant Probability
Favorable
1-2
OA Rounds
1y 9m
To Grant
99%
With Interview

Examiner Intelligence

Grants 93% — above average
93%
Career Allow Rate
508 granted / 545 resolved
+25.2% vs TC avg
Moderate +7% lift
Without
With
+6.9%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 9m
Avg Prosecution
16 currently pending
Career history
561
Total Applications
across all art units

Statute-Specific Performance

§101
2.5%
-37.5% vs TC avg
§103
28.2%
-11.8% vs TC avg
§102
35.6%
-4.4% vs TC avg
§112
25.2%
-14.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 545 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Drawings The drawings received on 07/15/2024 have been accepted by the examiner. Priority Receipt is acknowledged of papers submitted under 35 U.S.C. 119(a)-(d), which papers have been placed of record in the file. Information Disclosure Statement Acknowledgment is made of applicant's Information Disclosure Statement (IDS) Form PTO-1449, filed 07/15/2024. The information disclosed therein was considered. 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 & 5-7 & 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hiroshi et al (JP2018014376) in view of Toshiharu et al (JP2020181869). Regarding claim 1, Hiroshi discloses a magnetoresistive element comprising(FIG 1 & 7c; [0020] discloses MTJ element 10): a first magnetic layer; a second magnetic layer that changes between a perpendicular magnetization layer in which perpendicular magnetic anisotropy energy is positive(FIG 1; [0024-0026 & 0047] discloses 20 first(fixed), second 17 (recording) layers; wherein vertically magnetized if the magnitude Ku of vertical magnetic anisotropic energy is positive),and an in-plane magnetization layer in which the perpendicular magnetic anisotropy energy is negative( in-plane magnetized if negative), the perpendicular magnetic anisotropy energy determined on a basis of a difference between magnetic energy when magnetized in a plane direction of the layer and magnetic energy when magnetized in a direction perpendicular to the plane direction of the layer(the changes in magnetized according to the voltages applications, please see below), and a nonmagnetic layer disposed between the first magnetic layer and the second magnetic layer(FIG 7c; tunnel barrier 19 between fixed and recording layer (first 20 and second 17 layers), wherein the second magnetic layer: is the perpendicular magnetization layer when no voltage is applied to the magnetoresistive element; changes from the perpendicular magnetization layer to the in-plane magnetization layer when a first voltage is applied to the magnetoresistive element(FIG 1 & 7c; [0024-0026 & 0047; discloses layer 17 having vertical magnetization when a voltage is not being applied to 10 and transition to in-plane magnetization from vertical when Vc is applied to 10); and changes from the perpendicular magnetization layer to the in-plane magnetization layer when a second voltage is applied to the magnetoresistive element, magnetization of the second magnetic layer (transitions from vertical magnetization to in -plane magnetization when -Vc(second voltage) is applied to 10). However, Hiroshi does not disclose changes to a first direction of a direction perpendicular to a plane of the layer after a third voltage is applied to the magnetoresistive element for a first period of time; and changes to a second direction of the direction perpendicular to the plane of the layer after a fourth voltage is applied to the magnetoresistive element for a second period of time, the first voltage and the second voltage are in opposite directions to each other, and the third voltage and the fourth voltage are in opposite directions to each other. In the same field of endeavor, Toshiharu discloses changes to a first direction of a direction perpendicular to a plane of the layer after a third voltage is applied to the magnetoresistive element for a first period of time(FIG 17-18; [0022, 0053, 0107-0109] discloses bipolar voltage write, wherein magnetization of free layers changes to a first direction when a positive first write pulse is applied e.g., third voltage at time period e.g., OP1); and changes to a second direction of the direction perpendicular to the plane of the layer after a fourth voltage is applied to the magnetoresistive element for a second period of time(changes to a second direction when a negative second write pulse applied e.g., fourth voltage e.g,. OP2), the first voltage and the second voltage are in opposite directions to each other (positive and negative), and the third voltage and the fourth voltage are in opposite directions to each other (H1 and H2 direction e.g., up and down). Hiroshi and Toshiharu are analogous art because they are all directed to a magentoresistive memory device, and one of ordinary skill in the art would have had a reasonable expectation of success by modify Hiroshi to include Toshiharu because they are from the same field of endeavor. Therefore, it would be obvious to include the teachings of Toshiharu in the teachings of f Hiroshi for the benefits providing a magnetic element that has a high quality of power saving with an excellent high speed and stability [0019 Toshiharu). Regarding claim 2, The combinations of Hiroshi in view of Toshiharu discloses wherein the perpendicular magnetic anisotropy energy of the second magnetic layer: linearly decreases as a voltage applied to the magnetoresistive element approaches the first voltage from zero and changes from positive to negative at the first voltage(Hiroshi FIG 7c voltage applied to the 10 deceases linearly when approaching the voltage Vc from 0 e.g., vertical magnetization Ku changes from positive to negative at Vc) ; and linearly decreases as the voltage applied to the magnetoresistive element approaches the second voltage from zero and changes from positive to negative at the second voltage(-Vc to zero, and Ku changes from positive to negative at -Vc). Regarding claim 3, The combinations of Hiroshi in view of Toshiharu discloses wherein the first voltage and the third voltage are voltages in a same direction (Hiroshi first voltage positive Vc and Toshiharu third voltage positive write pulse), and the second voltage and the fourth voltage are in a same direction (Hiroshi second voltage negative -Vc and Toshiharu fourth voltage negative write pulse). Regarding claim 5, The combinations of Hiroshi in view of Toshiharu discloses wherein the first period of time is less than or equal to 100 ns, and the second period of time is less than or equal to 100 ns (Toshiharu FIG 18; [0023] teaches time line, and having restriction the time width of the voltage pulser for magnetizations reversal is relaxed e.g., first and second write pulse configured to be 100 ns or lower). Regarding claim 6, The combinations of Hiroshi in view of Toshiharu discloses wherein the magnetoresistive element has at least one of a mirror-symmetrical shape or a rotation-symmetrical shape when viewed in a stacking direction (Hiroshi FIG 1; [0027 & 0053] discloses in-plane shape having rotational symmetry and mirror symmetry). Regarding claim 7, The combinations of Hiroshi in view of Toshiharu discloses wherein the magnetoresistive element has at least one of a round shape, an elliptical shape, a square shape, or a rectangular shape when viewed in a stacking direction (Hiroshi FIG 1; [0027 & 0053] discloses in-plane shape having high symmetry as circle or ellipse). Regarding claim 10, Hiroshi discloses a magnetic memory comprising: a plurality of magnetoresistive elements(FIG 1 & 7c; [0020] discloses MTJ element 10s), wherein each of the plurality of magnetoresistive elements includes: a first magnetic layer(20); a second magnetic layer that changes between a perpendicular magnetization layer in which perpendicular magnetic anisotropy energy is positive FIG 1 & 7c; [0024-0026 & 0047; discloses layer 17 having vertical magnetization when a voltage is not being applied to 10 and transition to in-plane magnetization from vertical when Vc is applied to 10), and an in-plane magnetization layer in which the perpendicular magnetic anisotropy energy is negative (transitions from vertical magnetization to in -plane magnetization when -Vc(second voltage) is applied to 10), the perpendicular magnetic anisotropy energy obtained by subtracting magnetic energy when magnetized in a stacking direction from magnetic energy when magnetized in a plane direction of the layer the changes in magnetized according to the voltages applications, e.g., decreasing); and a nonmagnetic layer disposed between the first magnetic layer and the second magnetic layer, the second magnetic layer(FIG 7c; tunnel barrier 19 between fixed and recording layer (first 20 and second 17 layers): is the perpendicular magnetization layer when no voltage is applied to the magnetoresistive element(FIG 1 & 7c; [0024-0026 & 0047; discloses layer 17 having vertical magnetization when a voltage is not being applied to 10); changes from the perpendicular magnetization layer to the in-plane magnetization layer when a first voltage is applied to the magnetoresistive element(Vc); and changes from the perpendicular magnetization layer to the in-plane magnetization layer when a second voltage is applied to the magnetoresistive element, magnetization of the second magnetic layer (-Vc). However, Hiroshi does not disclose: changes to a first direction on a plane of the layer while a third voltage is applied to the magnetoresistive element; and changes to a second direction on the plane of the layer while a fourth voltage is applied to the magnetoresistive element, the first voltage and the second voltage are in opposite directions to each other, and the third voltage and the fourth voltage are in opposite directions to each other. In the same field of endeavor, Toshiharu discloses: changes to a first direction on a plane of the layer while a third voltage is applied to the magnetoresistive element(FIG 17-18; [0022, 0053, 0107-0109] discloses bipolar voltage write, wherein magnetization of free layers changes to a first direction when a positive first write pulse is applied e.g., third voltage at time period e.g., OP1); and changes to a second direction on the plane of the layer while a fourth voltage is applied to the magnetoresistive element changes to a second direction when a negative second write pulse applied e.g., fourth voltage e.g,. OP2), the first voltage and the second voltage are in opposite directions to each other (positive and negative), and the third voltage and the fourth voltage are in opposite directions to each other (H1 and H2 direction e.g., up and down). Hiroshi and Toshiharu are analogous art because they are all directed to a magnetoresistive memory device, and one of ordinary skill in the art would have had a reasonable expectation of success by modify Hiroshi to include Toshiharu because they are from the same field of endeavor. Therefore, it would be obvious to include the teachings of Toshiharu in the teachings of f Hiroshi for the benefits providing a magnetic element that has a high quality of power saving with an excellent high speed and stability [0019 Toshiharu). Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hiroshi et al in view of Toshiharu et al further in view of Yoshida et al (USJP2018055752). Regarding claim 8, The combinations of Hiroshi in view of Toshiharu discloses wherein, defining an external magnetic field that causes a direction of the magnetization of the second magnetic layer to substantially coincide with the plane direction of the layer as an effective anisotropic magnetic field(Hiroshi FIG 1 & 7c; [0024-0026 & 0047; discloses layer 17 having vertical magnetization when a voltage is not being applied to 10 and transition to in-plane magnetization from vertical when Vc is applied to 10; and changes from the perpendicular magnetization layer to the in-plane magnetization layer when a second voltage is applied to the magnetoresistive element, magnetization of the second magnetic layer (transitions from vertical magnetization to in -plane magnetization when -Vc (second voltage) is applied to 10). However, the combinations of Hiroshi in view of Toshiharu does not disclose an absolute value of the effective anisotropic magnetic field decreases substantially linearly as the voltage applied to the magnetoresistive element goes away from zero. In the same field of endeavor, Yoshida discloses an absolute value of the effective anisotropic magnetic field decreases substantially linearly as the voltage applied to the magnetoresistive element goes away from zero(FIG 4; [0026-0027 & 0036-0040] discloses magnetoresistive element performing write by an effect wherein magnetic anisotropy deceases by voltage application, and spin injection effect so that the anisotropic magnetic field exhibited by the magnetization free layer decrease linearly as the voltage far from zero e.g., voltage dependency). Hiroshi in view of Toshiharu and Yoshida are analogous art because they are all directed to a magnetoresistive memory device, and one of ordinary skill in the art would have had a reasonable expectation of success by modify Hiroshi in view of Toshibaru to include Yoshida because they are from the same field of endeavor. Therefore, it would be obvious to include the teachings of Yoshida in the teachings of f Hiroshi in view of Toshiharu for the benefits providing a low power consumption without applying external magnetic field to better the magnetroresistive (Abstract Yoshida). Allowable Subject Matter Claims 4 & 9 is 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 Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Kitagawa et al (US10840434 FIG 3; discloses resistance change element 22 having a non-magnet 130 and ferromagnet 140 layer having opposite directions write pluses applied to the layers). Yoshikawa et al (US12243572 FIG 5; disclose ferromagnetic layer 27a-1 has function of causing voltage control of magnetic anisotropy effect). Any inquiry concerning this communication or earlier communications from the examiner should be directed to MUNA A TECHANE whose telephone number is (571)272-7856. The examiner can normally be reached 571-272-7856. 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, Amir Zarabian can be reached at 571-272-1852. 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. /MUNA A TECHANE/Primary Examiner, Art Unit 2827
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Prosecution Timeline

Jul 15, 2024
Application Filed
Nov 28, 2025
Non-Final Rejection — §103
Apr 03, 2026
Response Filed

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
93%
Grant Probability
99%
With Interview (+6.9%)
1y 9m
Median Time to Grant
Low
PTA Risk
Based on 545 resolved cases by this examiner. Grant probability derived from career allow rate.

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