Prosecution Insights
Last updated: April 19, 2026
Application No. 18/769,841

LIQUID TREATMENT METHOD AND STORAGE MEDIUM

Final Rejection §102§103
Filed
Jul 11, 2024
Examiner
NGUYEN, HUNG
Art Unit
2882
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Tokyo Electron Limited
OA Round
4 (Final)
91%
Grant Probability
Favorable
5-6
OA Rounds
2y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 91% — above average
91%
Career Allow Rate
1313 granted / 1449 resolved
+22.6% vs TC avg
Moderate +9% lift
Without
With
+9.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
31 currently pending
Career history
1480
Total Applications
across all art units

Statute-Specific Performance

§101
1.7%
-38.3% vs TC avg
§103
40.6%
+0.6% vs TC avg
§102
32.0%
-8.0% vs TC avg
§112
14.5%
-25.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1449 resolved cases

Office Action

§102 §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 . 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. Claims 16-20, 22-23 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Kato et al (U.S.Pat. 8,623,146). As to claims 16 and 23, Kato discloses (figure 5A-6B) a liquid treatment method and a corresponding non-transitory computer readable storage medium and comprising all features of the instant claim such as: supplying cooling gas (71) while maintaining a state in which a treatment liquid (LF) remains on a substrate (W) and while maintaining the treatment liquid in a liquid state, from above the treatment liquid to at least a region relatively further inward than a peripheral edge portion of an upper surface (Wf) of the treatment liquid remaining on the substrate (figures 7A-C and 9A-C show gas supplied to inward radial positions, 0mm, 65mm, 100mm from center), so that the cooling gas is diffused in a radial direction rather than a circumferential direction of the substrate to adjust a temperature of a surface of the substrate (see col. 10, lines 10-25; Kato discloses the solidified region FR spreads radially outward from the initial position PR (IN) see figures 5B-6B) wherein an upper surface of the substrate to which the treatment liquid is supplied is not exposed by the supply of the cooling gas. It is noted that as shown in figures 5-8, Kato clearly discloses “the liquid film LF remains on the substrate W during supply of cooling gas; the cooling gas does remove the liquid film” (see col.10, lines 45-50). As to claim 17, Kato discloses adjusting a flow rate of the cooling gas and a flow velocity of the cooling gas while the cooling gas is supplied toward the treatment liquid remaining on the substrate, so that the upper surface of the substrate is not exposed by a movement of the treatment liquid due to the supply of the cooling gas (see col.11, lines 20-30). As to claim 18, Kato discloses wherein a maintenance period (TM2: Gas off) from creating, on an entirely of the substrate, a state in which the treatment liquid remains on the substrate to starting removal of the treatment liquid for the substrate includes a non-supply period during which the cooling gas is not supplied As to claim 19, wherein the non-supply period (TM2) is provided in a first half of the maintenance period. As to claim 20, Kato discloses wherein the supplying the cooling gas is performed while rotating the substrate (figures 5B, 6A, 7A-7C depict the substrate rotating during gas cooling) and wherein the supplying the cooling gas (71) includes supplying the cooling gas so that the cooling gas reaches a region on the substrate that does not include a center of the substrate. As to claim 22, Kato discloses a liquid film (LF) of DIW (deionized water) over the substrate (W) and also suggests to add a solidified film/treatment liquid. (see col.5, lines 5-7) 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 21 is rejected under 35 U.S.C 103 as being unpatentable over Kato et al (U.S.Pat. 8,623,146). With respect to claim 21, Kato discloses a treatment method comprising substantially all limitations of the instant claims as discussed. Kato does not expressly disclose the cooling gas is discharged at an incline angle with respect to the upper surface of the substrate from the cooling gas discharge port, as recited in the claim. However, Kato discloses that the cooling gas discharges from the nozzle (71) positioned above the substrate (W) and moves up and down and along the surface of the substrate (see figure 5B and 7A-7C). It would have been obvious to one having ordinary skill in the art before the effective filling date of the claimed invention to adjust the nozzle angle of the nozzle (71) of Kato for the purpose of controlling of gas flow distribution, size of the freeing region (FR) as well as the radial spread characteristics for improved cooling uniformity of the substrate. Response to Amendment/Arguments Applicant’s amendment filed February 26 has been entered. Claims 16 and 23 have been amended. Applicant’s arguments in conjunction with the amendment have been carefully reviewed but they are not found persuasive. Applicant argues that Kato fails to disclose “supplying a cooling gas while maintaining the treatment liquid in a liquid state”, asserting that the cooling gas disclosed in Kata causes the liquid film to freeze and therefore the liquid does not remain in a liquid state as required by amended claim 16. This argument is not persuasive. Kato discloses forming a liquid film (LQ) on the substrate surface and supplying cooling gas from a cooling gas discharge nozzle positioned above the liquid film (see, e.g., Figs 5A-5C and 6A-6B). During this process, the liquid film remains on the substrate while the cooling gas is supplied. Kato further explains that the freezing of the liquid film occurs progressively beginning with the formation of an initial solidified region (FRO) which spreads outward from the initial position (see col.10, lines 10-25). Because the solidification begins with the formation of an initial region and spreads radially outward, the liquid film necessary remains present on the substrate during the supply of cooling gas prior to and during the formation of the solidified region. Accordingly, Kato teaches supplying cooling gas while a treatment liquid remains on the substrate as recited in claim 16. It is noted that Applicant does not separately argue the patentability of dependent claims 17-22. Thus, the Examiner believes that they are not additionally patentable over and above the patentability of independent claim 16. Suggestion of drafted claim The following claim 16 is drafted by the examiner and considered to distinguish patentably over the art of record in this application, proposed claim 16 is presented to applicant for consideration: (Proposed Amended Claim 16) A liquid treatment method comprising: supplying a cooling gas, while maintaining a state in which a treatment liquid remains on a substrate and while maintaining the treatment liquid in a liquid state without solidifying the treatment liquid, from above the treatment liquid to at least a region relatively further inward than a peripheral edge portion of an upper surface of the treatment liquid remaining on the substrate, so that the cooling gas is diffused in a radial direction rather than a circumferential direction of the substrate to adjust a temperature of an upper surface of the substrate, wherein an entire area of the upper surface of the substrate where the treatment liquid is remaining is not exposed by the supply of the cooling gas. THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to HUNG HENRY NGUYEN whose telephone number is (571)272-2124. The examiner can normally be reached Monday-Friday 7:00AM-4:30PM. 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, Toan Minh Ton can be reached at 571-272-2303. 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. HUNG HENRY NGUYEN Primary Examiner Art Unit 2882 Hvn 3/10/26 /HUNG V NGUYEN/ Primary Examiner, Art Unit 2882
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Prosecution Timeline

Jul 11, 2024
Application Filed
Mar 10, 2025
Non-Final Rejection — §102, §103
Jun 16, 2025
Response Filed
Jul 27, 2025
Final Rejection — §102, §103
Oct 16, 2025
Applicant Interview (Telephonic)
Oct 16, 2025
Examiner Interview Summary
Oct 30, 2025
Request for Continued Examination
Nov 06, 2025
Response after Non-Final Action
Nov 21, 2025
Non-Final Rejection — §102, §103
Feb 26, 2026
Response Filed
Mar 10, 2026
Final Rejection — §102, §103 (current)

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

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Prosecution Projections

5-6
Expected OA Rounds
91%
Grant Probability
99%
With Interview (+9.0%)
2y 4m
Median Time to Grant
High
PTA Risk
Based on 1449 resolved cases by this examiner. Grant probability derived from career allow rate.

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