Prosecution Insights
Last updated: October 01, 2026
Application No. 18/958,125

PHASE CHANGE MEMORY CELL HAVING A HEATER WITH ACTIVATED RESISTANCE IN TEMPERATURE, AND IN-MEMORY COMPUTATION CIRCUIT USING SUCH A PHASE CHANGE MEMORY CELL

Non-Final OA §102§103
Filed
Nov 25, 2024
Examiner
PHAM, LY D
Art Unit
2827
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
STMicroelectronics N.V.
OA Round
1 (Non-Final)
94%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 94% — above average
94%
Career Allowance Rate
983 granted / 1046 resolved
+26.0% vs TC avg
Minimal +3% lift
Without
With
+3.4%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 9m
Avg Prosecution
20 currently pending
Career history
1054
Total Applications
across all art units

Statute-Specific Performance

§101
8.1%
-31.9% vs TC avg
§103
23.9%
-16.1% vs TC avg
§102
39.1%
-0.9% vs TC avg
§112
12.2%
-27.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1046 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 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 1 – 5, 10, 12 – 16 and 18 is/are rejected under 35 U.S.C. 102(a)(1) and 102(a)(2) as being anticipated by Song et al. (US Pat Pub 2020/0111839). Regarding claims 1 and 13, Song et al. disclose a phase change memory (PCM) cell (see for example figs. 1 – 9 and all related texts), comprising: a phase change material region (any of 21, 22, 23 or 24, fig. 2 for example); and a heater element coupled to phase change material region (for example region 11, 12, 13 or 14, fig. 2); wherein the heater element comprises a layer of an electrically conductive material having an activated resistance in temperature property (see para 0028, 0068, 0069. Conductive material is referred to as the electrodes of the heating elements 11, 12, 13 or 14. Heating by resistivities is discussed in para 0068, 0069, with current applied to induce heat); and wherein the electrically conductive material of the heater element is an alloy having a silicon content (see for example para 0036, 0038 and texts of claims 7 or 8, heater element electrode with Silicon content) in a range of 14 – 19 percent (para 0036 discloses in the case of third electrode 13, the Silicon content may be 13.5 – 16.5% and the 11.7 – 14.3% for the fourth electrode 14. The Silicon content taught to be used in these heating elements are in the ranged of the claimed 14 – 19%). Regarding claims 2 and 14, Song et al. also disclose the PCM cell of claim 1, wherein the activated resistance in temperature property of the electrically conductive material means that the heater element has a resistance in a first resistance range when the electrically conductive material is at a temperature within a first temperature range associated with operation of the PCM cell during memory read (inherently the electric heater element is not heated for read operation) and has a resistance in a second resistance range, different and lower than the first resistance range, when the electrically conductive material is at a temperature within a second temperature range, different and higher than the first temperature range, associated with operation of the PCM cell during memory programming (programming the PCM cell requires heating the heater element, hence it is inherent that the temperature when heated is higher than the first temperature when the heater is not heated. See for more details in para 0030). Regarding claims 3 and 15, Song et al. disclose the PCM cell of claim 2, wherein the first temperature range is less than 150 °C and the second temperature range is greater than 400 °C (this feature is considered inherent given the physical properties provided from the PCM cells with chemical characteristics given from claims 1 and 2, or 13 and 14). Regarding claims 4 and 16, Song et al. also disclose the PCM cell of claim 2, wherein the first resistance range is in a range of 1.E-2 to 1.E-1Qcm and the second resistance range is in a range of 1.E-4 to 1.E-3 Qcm (this is considered inherent given the resistance/temperature property and silicon content provided in claims 1 and 13). Regarding claim 5, Song et al. also disclose the PCM cell of claim 1, wherein the alloy of the electrically conductive material is substantially free of carbon (para 0043 discloses the conductive material alloy such as an alloy of Ge, Sb, and/or Te, or the like, without the inclusion of Carbon). Regarding claims 10 and 18, Song et al. also disclose the PCM cell of claim 1, wherein phase change material region is made of a germanium-antimony-tellurium (GST) alloy selected from the group consisting of a GST 225 alloy and a GST 447 alloy (see para 0030). Regarding claim 12, Song et al. also disclose an in-memory computation IMC device, comprising a memory array including a plurality of memory cells, wherein each memory cell of said plurality of memory cells is the PCM cell of claim 1 (see para 0003, memory devices including memory cells arranged in a 3-D structure…. See also para 0069). Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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) 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Song et al. (US Pat Pub 2020/0111839) in view of Tanizaki et al. (US Pat 2006/0209585). Regarding claim 9, Song et al. disclose the PCM cell of claim 1, except further comprising an access transistor coupled in series with the heater element and the phase change material region, wherein said access transistor is controlled as a current generator. This feature is however taught by Tanizaki et al. (fig. 2 discloses bit line current BL1 flowing through phase change element PCE and heating element HT through access transistor AT as controlled current generator. See also para 0104). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to combine the feature taught by the references as cited, so that reference current at the intermediate current value level can be produced reliably and stably without being influenced by the read disturbance, thereby the fast data reading can be performed, and reliability of the data reading can be improved (see para 0423). Claim(s) 11 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Song et al. (US Pat Pub 2020/0111839) in view of redaelli et al. (US Pat Pub 2025/0048940). Regarding claims 11 and 19, Song et al. also disclose the PCM cell of claim 1, except wherein the GST alloy is germanium rich having a stoichiometric percentage of Germanium in excess of 50%. This feature is taught by Redaelli et al. (see para 0026, 0043, 0048, etc…). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to combine the features taught by the prior references as cited, due to the fact that Ge-rich alloys is an increased advantage in crystallization temperature, providing an increased ability to preserve the stored logic state (phase retention) without degrading cycling performance. Allowable Subject Matter Claims 6 – 8, 17 and 20 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: The prior arts of record fail to teach or reasonably suggest the PCM cell and method of masking the PCM cell as set forth above, further comprising, in combination, the features and limitations additionally claimed at least in claims 6, 7, 17 and 20. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See additional cited references for related disclosures to the claimed invention. Any inquiry concerning this communication or earlier communications from the examiner should be directed to LY D PHAM whose telephone number is (571)272-1793. The examiner can normally be reached M-F: 8am-5pm. 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. LY D. PHAM Examiner Art Unit 2827 /LY D PHAM/Primary Examiner, Art Unit 2827 June 2, 2026
Read full office action

Prosecution Timeline

Nov 25, 2024
Application Filed
Oct 27, 2025
Response after Non-Final Action
Jun 05, 2026
Non-Final Rejection mailed — §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

1-2
Expected OA Rounds
94%
Grant Probability
97%
With Interview (+3.4%)
1y 9m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1046 resolved cases by this examiner. Grant probability derived from career allowance rate.

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