Atty_ Docket No. J'viiT-001-RXl
`
`IN THE UNITED STATES PATENT & TRADErv1ARK. OFFICE
`
`IN RE PATENT OF:
`
`Joseph BERNSTEIN et at
`
`PATENT NO.: 6,057,221
`
`SERIAL NO .. : 08/825,808
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`ISSUE DATE: 1-·1ay 2, 2000
`
`FILING DATE: April 3, 1997
`
`CONTROL NO.:
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`ASSIGNEES:
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`lvV\SSACHUSETTS INSTITUTE OF TECHNOLOGY;
`THE UNIVERSITY OF ?vfARYLAND
`
`FOR: LASER-ThtTIUCED CUTTING OF r-.·1ETAL INTERCONNECT
`
`I hereby certifY that this docmuent is being transmitted to the USPTO or deposited ·with the United States Postal
`Sen.'ice as first class mail in an envelope addressed to Commissioner for Patent&, P.O. Box 1450, Alexandria, VA
`22313-1450, otl1·1arch 30.2011 .
`
`By: ---------'-/_J_u_d_._y.___gyan_L__ ____ _
`Judy Ryan
`
`REQUEST FOR EX PARTE REEXA.1\.HNATION l.lNDER 35
`U.S.C 302 AND 37 C.F.R 1.510
`
`?\1fail Stop EX PARTE REEXAM
`COMlvllSSIONER FOR PATENTS
`P.O .. BOX 1450
`ALEXANDRIA, VA 22313-1450
`
`SIR:
`
`Reexainination of the above-identified patent is respectfully requested in view of the
`
`follO\ving statements and the accompanying Amendment.
`
`IPR2015-01087 - Ex. 1011
`Micron Technology, Inc., et al., Petitioners
`1
`
`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`Identification of Claims for Which Reexamination is Requested
`
`In accordance \Vith 37 C.F.R 1.510, reexamination of Claims 1-4 and 6-21 ofU.S. Patent
`
`No. 6,057,221 (hereinafter the ''"221 patent") is requested in view of the follO\ving references:
`
`U.S. Patents:
`
`•
`
`•
`
`•
`
`•
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`Lee et al., U.S. Patent No. 5,608,257 (hereinafter "Lee"):
`
`ft.
`"L ")
`.
`- 7,9 o· 4, 'h
`I lT S P . N
`ou eta ., •.. . alent
`·o. ), :.:. , ,. :.:. ( erema er
`ou · ;
`L
`
`rvkClure et al., U.S. Patent No. 4,.826, 785 (hereinafter "lv!cClure");
`
`Nishimura et al., U.S. Patent No. 5,872,389 (hereinafter "Nishimma").
`
`Foreign Patent Publications and Non-Patent Literature Documents:
`
`•
`
`Koyou, Japan Pat. Appl. Publ. No. 8-213465, published Aug. 20, 1996, and
`
`corresponding Non-Patent Literature Document (11ereinafter "NPL"), Cite No. l
`
`(hereinafter '"Koyou ");
`
`•
`
`•
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`l\:fatsumoto, Japan Pat. Appl. PubL No. 6-104338, published Apr. 15, 1994, and
`
`corresponding NPL, Cite No. 3 (hereinafter '"l\.{atsumoto"); and
`
`\Vada et aL Japan Pat. Appl. Publ. No. 6-244285, published Sep. 2, 1994, and
`
`corresponding NPL, Cite No.2 (hereinafter '"\Vada").
`
`Reexainination of the Claims in the '221 patent based on the above-cited references is
`
`requested as follmvs:
`
`I.
`
`Reexamination of Claims 1-2, 6-9, 11, 13-16, and 19-21 is requested in vie\v of
`
`Nishimura.
`
`2.
`
`3.
`
`4.
`
`5.
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`Reexamination of Claims 1 and 6-8 is requested in view ofWada.
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`Reexamination of Claim 1 is requested in view of :t-.·1atsmnoto.
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`Reexamination of Claim 1 is requested in view of Lee.
`
`Reexamination of C !aims 1 , 3-4 and ll is requested in vie\v of Koyou.
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`Page 2 of68
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`2
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`6.
`
`Reexamination of Clain:1s 10, 17-18 and 21 is requested in view of Nishimura and
`
`Koyou.
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`7.
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`Reexamination of Claims 10, 16 and 21 is requested in view of Nishirnura and
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`\\rada.
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`8.
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`Reexamination of Claims 12-13 and 19 IS requested m v1ev-.r of \Vada and
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`rvkClure.
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`9.
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`Reexamination of Claims 12-15 and 19 is requested in view of\Vada and Lou.
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`10.
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`11.
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`12.
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`13.
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`14.
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`15.
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`Reexamination of Claim 12 is requested in vie\v of Nishimura and McClure.
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`Reexamination of Claim 12 is requested in view ofNishimura and Lou.
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`Reexamination of Claims 17-18 is requested in vie\v ofKo)'OU and McClure.
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`Reexamination ofClaims 17-18 is requested in vie\v ofKoyou and Lou.
`
`Reexamination of Claim 21 is requested in vie\:v ofWada, 1\.kClure and Koyou.
`
`Reexamination of Claim 21 is requested in vie\:v ofWada, Lou and Koyou.
`
`For the reasons given herein, Claims 3-4, 11, 14-15 and 17-18 of the '221 patent are
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`enforceable and.i'or patentable; Claims 6-8, 13 and 21 as amended are enforceable and/or
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`patentable; and new Claims 22-29 are enforceable anrLlor patentable.
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`Page 3 of68
`
`3
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`Statement Pointing Out Each Substantial New Question of Patentability
`
`Each of the references listed above is believed to raise a substantial ne\v question of
`
`patentability (hereinafter "SNQ") as to claims of the '221 patent as detailed in this Statement
`
`Except for Lee, none of the references cited above were of record in the prior concluded
`
`examination ofthe '221 patent.
`
`Prosecution Histon' Summan'
`
`The application for the •221 patent (U.S. Pat. AppL No .. 08/825,808; hereinafter, the
`
`"'808 application") \Vas filed on April 3, 1997. On April 14, 1999, the Examiner issued a
`
`Restriction Requirement requiring restriction to one of the follmving two groups: Group I
`
`(Claims 20-41) draw1.1 to a method of n1:1king a semiconductor device; and Group II (Claims 1-
`
`19) dra\'Vn to a semiconductor device. In response, Patentees elected Group I (Claims 20-41),
`
`drawn to a method of making a semiconductor device.
`
`Claim 20, the sole independent clain:1 remaining after Patentees' election, recited (at the
`
`time of the election) a method for cutting a link behveen interconnected circuits comprising the
`
`steps of directing a laser upon an electrically-conductive cut-link pad conductively bonded
`
`betv,,een a first electrically-conducti·ve line and a second electrically-conductive line on a
`
`substmte, the cut-link pad having substantially less thermal resistance per unit length than each
`
`of the flrst and second lines, and maintaining the laser upon the cut-link pad until the laser
`
`infitses suUicient energy into the cut-link pad to break the conductive link across the pad
`
`betv,,een the pair of electrically conductive lines.
`
`On Jtme 3, 1999, the Examiner issued an Office Action related to the remaining pending
`
`claims (hereinafter the "Office Action"). In the O±Iice Action, the Exa1niner rejected Claims 20-
`
`24, 32-33 and 36-38 under 35 U.S.C. § 102(e) as being anticipated by Lee, and objected to
`
`Claims 25-31, 34-35 and 39-41 as being dependent upon a rejected base claim (Clain:l20). In the
`
`Office Action, the Examiner indicated that although the stmcture of the fitse disclosed by Lee is
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`Page 4 of68
`
`4
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`not identical to that disclosed in the '808 application, "claim 1 as \Yorded reads on Lee et al
`
`because the invention of Lee is directed tmvards a fuse absorbing a greater amount of the laser
`
`energy than the surrounding elements, siiTillar to claim 1 as \Yorded" (Office Action, p. 3, first
`
`paragraph). At the time of the Oflice Action, Claim 20 was drava1 to a method of cutting a link
`
`bet\veen interconnected circuits, and recited limitations si1.nilar to the limitations of Claim 1,
`
`drawn to an electrical interconnect
`
`Additionally, the Examiner indicated that \'Vhile there was prior art disclosing "the use of
`
`a cut-link pad having greater thennal conductivity than the conductive lines," Claims 31 and 41
`
`\Vere distinguishable over these prior mt references (Office Action, p. 5, first full paragraph).
`
`Specifically, the Examiner noted that Sur, Jr. et al. (U.S. Pat. No. 5,882,998) "teaches the use of
`
`a thin silicide layer in the fuse region, but here the fuse is cut by an electrical current, \Vhich is
`
`dif:l:erent than the instant invention \'Vhich uses a laser" (Oflice Action, p. 5, first full paragraph).
`
`Shiozaki et al. (U.S. Pat No. 4,682,204) "teaches that the filse has an i11creased heat capacity ....
`
`Hmvever, the stmcture used in Shiozaki et a! is a composite, made up of an oxide \Vith grooves
`
`and a polysilicon layer disposed inside of the grooves to alter the heat capacity. This differs
`
`from the instant invention in that the instant invention discloses the use of a single, continuous
`
`material" (Office Action, p. 5, first full paragraph). While Patentees agree that the claims of the
`
`''221 patent are distinguished from Shiozaki et al., Patentees do not necessarily agree \Vith the
`
`characterization of the Exanilner \'Vith regard to the use of a si11gle, continuous material (for
`
`example, the claims of the '221 patent use the open-ended transitional term "comprising,"
`
`meaning that additional materials can be present in the cut-link pad).
`
`As to Claims 34 and 35, the Examiner noted that although Cot1ey et al. (U.S. Pat. No.
`
`5,070,392; hereinafter Cotley) "discusses the use of a silicon nitride layer disposed upon the
`link, f ] there is a portion of the silicon nitride layer \Vhich is removed to allow for laser cutting
`f citation omitted]. The technique of Cofley et al is ditlerent from the instant invention i11 that in
`the instant invention, the silicon nitride layer is maintained over the cut-link" (Oflice Action, p.
`
`5, second fuJI paragraph).
`
`Page 5 of68
`
`5
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`

`
`Atty. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
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`Further, the Examiner indicated that Claims 25-31, 34-35 and 39-41 ,:vould be allowable
`
`if rewritt.en in independent fmm including all of the limitations of the base claim and any
`
`inte1\<'ening claims. Specifically, the Exa1niner indicted that "the prior art either singly or in
`
`combination fails to anticipate or render obvious the limitations of claims 25-30 and 30-40, that
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`the width of the cut-link pad is fll least a predetermined percentflge greater titan the width of
`
`each of the first and second electricallv-conductive lines" (Office Action, p. 4, paragraph 4;
`
`emphasis added).
`
`In making the detennination of allmvable subject matter, the Examiner
`
`assumed that the cut-link pad of the '808 application "is a simple continumts shape having no
`
`projections extending away therefrom," \'Vhereas Lee "discusses the use of 'fins' and \Vhile these
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`'fins' are not \Yider than the conductive lines, they absorb more of the incident laser energy,
`
`similar to the instant invention" (Office Action, p. 4, paragraph 4). \Vhile Patentees agree that
`
`the claims of the ''221 patent are distinguished from Lee (e.g., for reasons discussed herein),
`
`Patentees do not necessarily agree \'Vith the characterization of the Examiner \Vith regard to the
`
`use of a simple continuous shape having no projections extending mvay therefrom (for example,
`
`the claims of the '221 patent use the open-ended transitional tenn "comprising," meaning that
`
`the cut-link pad can include additional parts or have a relatively complex stmcture; also, Claim
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`11 of the '221 patent, \Vhich the Examiner allmved, recites that the cut-link pad is fonned of a
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`material that has greater thennal conductivity' than the material that fmms each of the first and
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`second electrically-conductive lines, \Vhich does not exclude the possibility that the cut-link pad
`
`can have a relatively complex structure).
`
`In response, Patentees filed an Amendment and Remarks on September 30, 1999,
`
`amending Clain:1s 20, 31 and 33-34, and cancelling Clain:1 25. In their Ren:mrks, Patentees noted
`
`that Claim 20 (Claim 1 in the issued '221 patent) had been amended to add the limitation of the
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`original, allmvable Claim 25 (that the width of the cut-link pad is at least 10~~ greater the width
`
`of each of the first and second electrically-conducti,,e lines), that allowable Claim 31 (Claim 11
`
`in the issued '221 patent) \Vas re\'Vritten in independent fonn, and that allmvable Claim 34 (Claim
`
`14 in the issued '221 patent) ,:vas re\vritten in independent fonn.
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`Page 6 of68
`
`6
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`On December 8, 1999, the Examiner issued a Notice of Allo\:vability (hereinafter,
`
`"Notice") indicating that Claims 20-24 (subsequently' renumbered as Claims 1-5) and Claims 26-
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`41 (subsequently renumbered as Claims 6-21) were allmved. The Examiner indicated that '"by
`incorporating the shape of the cut-link pad into the independent claim, said claim [is J allmvable"
`(Notice, p. 2, item 2, second paragraph). Again, Patentees do not necessarily agree with the
`
`Examiner's characterization of the independent daim(s) (i.e., that the shape of the cut-link pad
`was incorporated into the independent claim[ s D.
`
`1.
`
`A SNQ as to Claims 1-2. 6-9, 11, 13-16 and 19-21 is believed to be raised in vie\v of
`Nishimura:
`
`Nishimura \Vas filed before and/or dailns the benefit of a U.S. tiling date that is before
`
`the filing date of the '221 patent and \Vas not cited ii1 the prosecution ofthe ''221 patent.
`
`Claims 1-2 and 6-7:
`
`Claim 1 of the •221 patent recites a method for cutting a link between interconnected
`
`circuits comprising the steps of directing a laser upon an electTically-conductive cut-link pad,
`
`conductively bonded between a flrst electrically-conductive line and a second electrically(cid:173)
`
`conductive line on a substrate, the cut-link pad havii1g substantially less thermal resistance per
`
`unit length than each of the first and second lines, 1vherein the 1vidth (?l the cut-link pad is at least
`
`ten percent greater than the ·width qf each qf the first and second elech'ical(v-conductive lines,
`
`and maintaining the laser upon the cut-link pad until the laser infuses sufficient energy into the
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`cut-link pad to break the conductive link across the pad bet\veen the pail· of electrically
`
`conducti·ve lines (see col. 9, ll. 49-62 ofthe '221 patent; emphasis added). Claim 2 depends fium
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`Claiml and adds the limitation that the electrically-conductive cut-link pad lies in the same plane
`
`as the first and second electTically-conductive lines. Clain:1 6 depends from Claim 1, and adds the
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`limitation that the \vidth of the cut-link pad is at least hventy-five percent greater than the width
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`of each of the first and second electrically-conductive lines (see coL 10, lL 13-16 of the •221
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`Page 7 of68
`
`7
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`patent). Claim 7 depends from Claim 1 and adds the limitation that the width of the cut-link pad
`
`is at least flfl:yr percent greater than the \Vidth of each of the first and second electrically(cid:173)
`
`conductive lines (see col. 10, 11. 17-19 ofthe '221 patent).
`
`The references of record do not disclose or suggest that the width of the cut-link pad is at
`
`least a predetermined percentage greater than the \vidth of each of the fJ.rst and second
`
`electrically-conductive lines, as noted by the Examiner in the prosecution of the '808 application
`
`(see OHice Action, p. 4, paragraph 4). However, Nishimura discloses a f"l1se having a first
`
`portion 2a of a relatively large planar width \'ll and second pmtions 2b having a relatively small
`
`planar \'Vidth \V2 on both sides of the first portion 2a (see coL6, ll. 28-32 and FIGS. 3 and 4 of
`
`Nishimura). Specifically, tvhen the value q{TYJ...lfY2 is 2 or more (i.e. \Vhen the \Vidth ofthe first
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`pmtion of the fuse is 100~~ greater than the second pmtions), the value of the maxin:uun diameter
`
`D of the blovvn hole is significantly' reduced (see col. 7, II. 10-12 of Nishimura; emphasis added).
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`Nishimura also discloses and.ior suggests that the first portion 2a of the fuse lies in the same
`
`plane as the fJ.rst and second electrically-conductive lines (see FIG. 4 of Nishimura).
`
`The abo·ve disclosures by Nishimura \Vere not considered by the Examiner m the
`
`application of the art in the prior concluded examination (i.e., the disclosures are '"new"), and
`
`Patentees believe that a reasonable examiner may consider these disclosures important in
`
`determining \Vhether or not Clain:1s 1-2 and 6-7 are patentable. For these reasons, Nishin:mra is
`
`believed to raise a substantial ne\v question of patentability as to Claims 1-2 and 6-7 of the '221
`
`patent
`
`Claims 8-9:
`
`Claim 8 depends fiom Claim 7 (which depends from Claim 1) and adds the limitation
`
`that 1he cut-link pad comprises a composition substantially identical to the composition of the
`
`fJ.rst and second electrically-conductive lines (see col. 10, 11. 20-23 of the '221 patent). Claim 9
`
`depends hom Claim 8 and adds the limitation that the substrate is planar and the \vidth of the
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`Page 8 of68
`
`8
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
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`cut-link pad is \Vithin 200,-6 of the length of the cut-link pad (see coL lO, 11. 24-26 of the '221
`
`patent}
`
`The references of record. do not disclose or suggest that the \vidth of the cut-link pad is at
`
`least a predetermined percentage greater than the width of each of the first and second
`
`electrically-conductive lines (as recited in Claim 1), as noted by the Examiner in the prosecution
`of the ·sos application (Office Action, p .. 4, paragraph 4). Furthermore, the references of record
`do not disclose or suggest a cut-link pad having (1) a composition substantially identical to the
`
`cmnposition of the first and second electrically-conductive lines (Patentees do not necessarily
`
`agree \Vith the Examiner's characterization that the claimed fuse is made up of a single,
`
`continuous material: see the Office Action, p. 5, first full paragraph), or (2) a length that is a
`
`predetermined percentage of the \Yidth of the cut-link pad (see e.g .. , Alberts et al., U.S. Pat. No.
`
`3,959,047, Nicolay, U.S. Pat. No. 4,198,744 and Takagi, U.S. Pat. No. 4,748,491).
`
`Reexamination of Claims 1 and 7 has been requested in view of Nishimura (see the
`
`discussions of Nishin:mra as applied to Clain:1s 1 and 7 above, incmvorated herein by reference).
`
`Nishimura also discloses that "the base of the fuse layer 2 in accordance \Vith the fourth
`
`embodiment is formed by a layer 2e of a material having a relatively large laser absm}Jtion
`
`coefficient" (coL 8, ll. 9-15 and FIG. 9B ofNishimura). Nishimura fl.uther discloses that "since
`
`mainly the first pm1ion 2a is blmvn ... it becomes possible to reduce the n:mxinmm diameter D of
`
`the blmvn hole 7 by maki-ng small the length L of the first portion 2a" (col. 6, 11. 55-58, and
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`FIGS .. 3 and 5 ofNishimura; emphasis added).
`
`These disclosures by Nishimura ,:vere not considered by the Examiner in the application
`
`of the rut in the prior concluded examination (i.e., the disclosures ru·e "new"), and Patentees
`
`believe that a reasonable examiner may consider these disclosures important in determining
`
`\Vhether or not Claims 8-9 are patentable. For these reasons, Nishimura is believed to raise a
`
`substantial ne\v question of patentability as to Claims 8-9 ofthe '221 patent.
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`Page 9 of68
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`9
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Claim 11:
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`Serial No.: 08/825,808
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`Independent Claim 11 recites a method for cutting a link bet\veen interconnected circuits,
`
`comprising directing a laser upon an electrically-conductive cut-link pad conductive!)' bonded
`
`ben:veen a first electrically-conductive line and a second electTically-conductive line on a
`
`substrate, the cut-link pad having substantially less thermal resistance per unit length than each
`
`of the first and second lines, lvherein the cut-link pad is formed of a material that has greater
`
`thermal conductivity than the material that forms each of the first and second electrica#v-
`
`conductive lines; and 1.naintaining the laser upon the cut-link pad until the laser infilses sufficient
`
`energy into the cut-link pad to break the conductive link across the cut-link pad between the pair
`
`of electrically-conductive lines (see coL 10, ll. 30-44 of the '221 patent; emphasis added).
`
`The references of record do not disclose or suggest a cut-link having greater thennal
`
`conducti·vity than the conductive lines thereto, fonned of a continuous material and cut by a laser
`
`(see Ot11ce Action, p. 5, first full paragraph). Ho,:vever, Nishimura discloses a fuse having a first
`
`portion 2a and second pmtions 2b on both sides of the tirst portion 2a (see col. 6, lL 28-32, and
`
`FIGS. 3 and 4 of Nishimura). Nishimura also discloses that "the planar width \Vl of the first
`
`portion 2a is larger than the planar width of the second portion 2b ... " (see col. 6, lL 39-40 of
`
`Nishimura; compare FIG. 3 of Nishimura and FIG. 3 of the '221 patent), which appears to
`
`suggest that the first portion has less then11:1l resistance than the second portions 2b. Fm1her,
`
`Nishimura discloses that the f"l1se layer 2 has a high absorbing portion 2c and low absorbing
`
`portions 2d provided on both sides of the high absorbing portion 2c. '"High absorbing pm1ion 2c
`
`is fonned of a material having relatively large laser absorption coef1icient, such as ttmgsten
`
`silicide or titanimn silicide. Lmv absorbing portion 2d is fanned of a material having a relatively
`
`small laser absorption coefficient, such as amorphmts silicon or polycrystalline silicon." Col. 7,
`
`ll. 42-50, and FIG. 8 of Nishimura.
`
`These disclosures by Nishimura ,:vere not considered by the Examiner in the application
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`of the m1 in the prior concluded examination (i.e., the disclosures are "new"), and Patentees
`
`believe that a reasonable examiner may consider these disclosures important in detetmining
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`Page 10 of68
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`10
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`

`
`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
`
`Serial No.: 08/825,808
`
`whether or not Claim 11 of the •221 patent is patentable. For tllis reason, Nishimura is believed
`
`to raise a substantial ne\v question of patentability as to Claim II of the '22I patent
`
`Claims 13, 16 and 1.9-21:
`
`Claim 13 depends from Claim 1 and adds the li1.nitation that a passivation layer covers
`the cut-link pad (see col. 11, lL 47-48 of the '221 patent). Claim 16 depends fiom Claim 13 and,
`
`similarly to Claim 2, adds the limitation that the electrically-conductive cut-link pad lies in the
`
`same plane as the first and second electrically-conductive lines (see col. 10, 11. 65-67 ofthe '221
`
`patent). Claims 19-21 also depend from Claim 13. Claim 19, similarly to Claim 7, adds the
`
`linlitation that the width of the cut-link pad is at least fifty percent greater than the width of each
`of the first and second electrically-conductive lines (see coL 11, lL 9-ll of the '221 patent).
`
`Claim 20, similarly to Claim 9, adds the limitation that the substrate is planar and the \vidth of
`
`the cut-link pad is \'Vithin 20~'o ofthe length of the cut-link pad, the length being measured as the
`distance across the cut-link pad ben.veen the first and second lines (see coL 12, 11. 1-5 ofthe '221
`
`patent). Claim 21, similarly to Claim11, adds the limitation that the cut-link pad is comprised of
`
`a material \Yith greater the1mal conductivity than the material comprising each of the first and
`second electrically-conductive lines (see coL 12, lL 6-9 of the '221 patent).
`
`The references of record. do not disclose or suggest that the \vidth of the cut-link pad is at
`
`least a predetermined percentage greater than the width of each of the first and second
`
`electrically-conductive lines (as recited in Claim 1; see OHice Action, p. 4, paragraph 4).
`
`Additionally, the references of record do not disclose or suggest a cut-link pad \Vith an increased
`
`heat capacity formed from a single, continumts n1:1terial and cut by a laser (Office Action, p .. 5,
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`first fl.Ill paragraph). HO\vever, it appears that Yoo et aL, U.S. Pat No. 5,578,517 (cited in the
`
`file \Vrapper of the ''221 patent; hereinafter '"Yoo") discloses a protective film 50, formed of
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`PECVD silicon nitride, deposited in an opening 48 over fuse 26 (coL 6, lL 12-17, and FIG. 6).
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`Reexamination of Claims I-2, 7, 9 and 11 has been requested in viev-.r of Nishimura (see
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`the discussions ofNishimura as applied to Claims 1-2, 7, 9 and 11 above, incorporated herein by
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`Page II of68
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`11
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`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
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`Serial No.: 08/825,808
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`reference). Additionally, Nishimura discloses an insulating layer 3b covering the tl1se layer 2,
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`which may be fonned of silicon oxide or silicon nitride (see col. 4, 11. 38-42 and coL 8, ll. 22-25).
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`These disclosures by Nishimura \'Vere not considered by the Examiner in the application
`
`of the a11 in the prior concluded examination (i.e., the disclosures are '"new"), and Patentees
`
`believe that a reasonable examiner may consider these disclosures important in determining
`
`whether or not Claims 13, 16 and 19-21 of the •221 patent are patentable. For these reasons,
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`Nishimura is believed to raise a substantial new question of patentability as to Claims 13, 16 and
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`19-21 ofthe '221 patent
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`Claims 14-15:
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`Independent Claim 14 claims a method for cutting a link bet\veen interconnected circuits
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`comprising the steps of directing a laser upon an electTically-conductive cut-link pad
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`conducti·vely bonded betv,,een a first electricall~.r-conductive line and a second electrically(cid:173)
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`conducti·ve line on a substrate, the cut-link pad having substantialf:v less thermal resistance per
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`unit length than each of the jlrst and second lines, 1-vlwrein the cut-link pad is covered H'ith a
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`passivation layer that is harder than the substrate, and maintaining the laser upon the cut-link
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`pad until the laser infitses sufficient energy into the cut-link pad to break the conductive link
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`across the cut-link pad behveen the pair of electrically-conductive lines (see coL 10, ll. 49-62 of
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`the '221 patent; emphasis added). Claim 15 depends from Claim 14 and adds the limitation that
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`the passivation layer is comprised of silicon nitride (see col. 10, 11. 63-64 of the '221 patent).
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`The references of record do not disclose or suggest a cut-link pad having substantially
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`less thermal resistance per unit length than each of the first and second lines, \Vherein the cut-link
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`pad is covered \Vith a passivation layer (e.g., a silicon nitride layer) that is harder than the
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`substrate (silicon nitTide is a harder than, for example, silicon oxide) and that is maintained over
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`the cut-link pad during laser cutting (Office Action, p. 5, second full paragraph). It is noted that
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`Yoo (discussed above \Vith regard to Claims 13, 16 and 19-21) fmther discloses a first insulating
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`layer 40 (preferably formed of thick silicon oxide) over ,:vhich fttse 26 is formed (col. 4, lL 41-
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`Page 12 of68
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`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
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`Serial No.: 08/825,808
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`52). However, Nishimura discloses that "on a main surface of a semiconductor substrate 1, fuse
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`layer 2 is fmmed \Vith interlayer insulating layer 3a inteiposed" (coL 4, ll. 33-35 and FIG. 1 of
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`Nishimura), and '"[t]hough insulating layer 3b is fonned of silicon oxide ... the concept of the
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`present invention can be applied even \Vhen the insulating layer 3b is fonned of other materials
`
`such as silicon nitride" (coL 8, 11. 22-25 ofNishimura).
`
`The above disclosures by Nishimura \Vere not considered by the Examiner in the
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`application of the art in the prior concluded examination (i.e., the disclosures are "nev/'), and
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`Patentees believe that a reasonable exaininer might consider these disclosures important in
`
`determining \Vhether or not Claims 14-15 of the '221 patent are patentable. For these reasons,
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`Nishimura is believed to raise a substantial ne\v question of patentability as to Claims 14-I5 of
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`the '221 patent.
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`2.
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`A SNO as to Claims 1 and 6-8 is believed to be raised in vie\v of Vhda
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`Wada \'Vas published in Japan prior to the filing date ofthe '221 patent and \Vas not cited
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`in the prosecution of the '221 patent.
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`The limitations of Claims I and 6-8, and the disclosures of the references of record
`
`applicable to Claims 1 and 6-8, are discussed in SNQ No. I above, incorporated herein by
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`reference. Vhda discloses that '"redundancy fuse 1 is fanned of a fusing portion 1a and non(cid:173)
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`fusing portion[ Js [sic] lb ... The fusing portion 1a is continuously provided between the non(cid:173)
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`fusing portions I b on both sides thereof so as to overlap an inadiation region 4 of a laser beam ...
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`A \'Vidth of the fusing portion 1 a is set to be larger than a \vidth of the non-fusing portions I b"
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`(para. [0010] and FIG. 1 of \\lada). «Specifically, the \Yidth of the non-fusing portion 1b is
`
`approximately 1 ~un ... if the iiTadiation region 4 of the laser light is set to be an area of a circle
`
`with the diameter of 3 !Hll, the area of the fusing portion 1 a is set to be approxin:mtely 60%1
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`thereo( being a square with one side of 2 pm." Para. [0010] of\Vada. \Vada further discloses "a
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`non-fttsing portion \Yithin an irradiation region of the energy beam provided on both ends of the
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`Page I3 of68
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`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
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`Serial No.: 08/825,808
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`fusing region and has, in one portion, a region with higher heat resistance than heat resistance of
`
`a periphery." Para. [0007] of\Vada.
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`These disclosures b)' \Vada \Vere not considered by the Examiner in the application of the
`
`art in the prior concluded examination (i.e., the disclosures are "new"), and Patentees believe that
`
`a reasonable examiner might consider these disclosures important in detennining whether or not
`
`Clain:1s 1 and 6-8 are patentable. For this reason, these disclosures by \\lada are believed to raise
`
`a substantial nev-.r question of patentability as to Claims 1 and 6-8 of the '221 patent.
`
`3.
`
`A SNQ as to Claim 1 is believed to be raised in view of:rviatsmnoto
`
`Matsumoto was published in Japan prior to the tiling date of the '221 patent and \Vas not
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`cited in the prosecution of the '221 patent.
`
`The limitations of Claim 1, and the disclosures of the references of record applicable to
`
`Clain:1 I, are discttssed in SNQ No. 1 above, inco:rporated herein by reference. Matsumoto
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`discloses a f"l1se element 1 for a circuit fmmed in a shape having a larger width in the center
`
`portion of the fitse element than the \vidth on both end pmtions thereof (see para. [0010] and
`
`FIG. 1 of Matsumoto). lv!atsumoto firrther discloses that the \vidth D of both end pmtions of the
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`fuse element 1 is 2 gm and the width \\r of the fitse element 1 is approximately 4 ~un (para.
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`[0010] of Matsumoto).
`
`These disclosures by lv!atsumoto \Vere not considered by the Examiner in the application
`
`of the a11 in the prior concluded examination (i.e., the disclosures are '"new"), and Patentees
`
`believe that a reasonable examiner might consider these disclosures important in detennining
`
`whether or not Claim I is patentable. For this reason, these disclosures by :rviatsmnoto are
`
`believed to raise a substantial ne\:v question of patentability as to Claim 1 of the '221 patent
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`Page 14 of68
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`14
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`Att.y. Docket No. MIT -00 1-R.X 1
`U.S. Patent No.: 6,057,221
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`Serial No.: 08/825,808
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`4.
`
`A SNQ a.s to Claim I is believed to be raised in view of Lee
`
`Lee \Vas filed before and/or clain:1s the benefit of a U.S. filing date that is before the filing
`
`date of the '221 patent. Lee \Vas cited in the prosecution of the '221 patent.
`
`The limitations of Claim 1, and the disclosures of the references of record applicable to
`
`Claim 1, are discussed in SNQ No. 1 above, incorporated herein by reference. Lee discloses "a
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`fuse stmcture programmable b)' a laser beam that includes a melt-a\vay elongated fuse link
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`joining 1:\vo segments of an interconnecting line ... " (Abstract of Lee), and addresses the issue of
`
`damage to a semiconductor substrate resulting from absorption of a high percentage of incident
`
`laser radiation by increasing the area of the fuse. See, e .. g., col. 2, 11. 5-8 and 57-61, col. 3, 11. 49-
`
`58, and FIGS. 2A-2D of Lee. To increase the area of the fuse, Lee discloses '"[a] fuse link
`
`having a naiTmv neck 24, modified to include a series of fins 12 protmding from the neck of the
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`fuse as shown ... a combination of long and short fins (12 and 16, respectively) may be used."
`
`Col. 4, 11. 20-25 and 28-30, and FIGS. 2A-2D of Lee.
`
`As discussed above, the Exmniner in the prior concluded examination rejected claims
`
`under 35 U.S.C. § l02(e) based on Lee, but in so doing assumed that the cut-link pad of the '808
`
`application "is a simple continuous shape having no projections extending away thereiron:L. .. "
`
`(Office Action, p. 4, paragraph 4). The Examiner concluded that the prior art failed to anticipate
`
`or render obvious claims \Vhich included the limitation that the \vidth of the cut-link pad is a
`
`predetermined percentage greater than the wid1h of each of the tirst and second electrically(cid:173)
`
`conductive lines. (OHice Action, p. 4, paragraph 4).
`
`Again, Patentees agree that the claims of the '221 patent are distinguished ft