Docket No. 10031.004211
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`Reply Brief
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`First Named Inventor:
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`Peter John COUSINS
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`Application No.:
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`14/504,771
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`Examiner:
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`PILLAY, DEVINA
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`Filing Date: October 2, 2014
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`Art Unit:
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`1757
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`Title: FRONT CONTACT SOLAR CELL WITH FORMED EMITTER
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`REPLY BRIEF FILED UNDER 37 C.F.R. § 41.41
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`This Reply Brief is responsive to the Examiner’s Answer mailed March 19, 2018,
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`and follows the Appeal Brief submitted by the appellant on November 8, 2017.
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`Docket No. 10031.004211
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`Reply Brief
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`REMARKS
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`This Reply Brief responds to the contentions in the Examiner’s Answer. Detailed
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`explanations why the pending claims are patentable over the references of record are
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`provided in the Appeal Brief, and not repeated here in the interest of clarity and brevity.
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`A.
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`CLAIMS 1-4, 7, 9-12, and 14
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`Claims 1—4, 7, 9-12, and 14 are rejected under pre-AIA 35 U.S.C. §103(a) as
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`being unpatentable over Meier (US 6,262,359), in View of Okayasu (JP 07-106611), in
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`view of Borden (US WO 2009/094578 A2) and further in view of Wenham (US
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`6,429,037). The rejection is respectfully traversed.
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`1.
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`Backside junction emitter with tunnel dielectric
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`Claim 1 is patentable over the combination of Meier, Okayasu, Borden and
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`Wenham at least for reciting: “a tunnel dielectric disposed over the back surface of the
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`substrate; an emitter disposed over the tunnel dielectric, the emitter forming a backside
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`junction with the substrate.” Claim 1 recites a structure of a solar cell. In the
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`embodiment of claim 1, the solar cell has an emitter that is disposed over a tunnel
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`dielectric and forms a backside (i.e., the side opposite the light incident side) junction
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`with the substrate.
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`The drawing on page 10 of the Examiner’s Answer shows the extent of the
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`proposed modification to Meier. Comparing Meir’s original structure,
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`222
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`HQ. 30
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`222
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`to the modified structure,
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`Docket No. 10031.004211
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`Reply Brief
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`First, in the original structure, the backside junction 224 is formed by an N—type
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`base layer 218 and a P-type layer 220, both of which are within an N-type single crystal
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`silicon substrate (Meier, column 5, lines 43-49). There is no intervening material, such as
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`the tunnel oxide layer and the P—type polycrystalline layer in the modified structure,
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`between the P-type layer 220 and the N—type base layer 218 because it would block
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`contact of the aluminum contact layer 222 to the substrate to form the P-type layer 220
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`therein as taught by Meier (Meier, column 6, lines 46-66).
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`Second, the original structure has a P—type layer ’220 Within the silicon substrate,
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`whereas the P—type layer 220 is external to the substrate in the modified structure. With
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`regards to solar cell backside structures, Okayasu discloses an alternative way of forming
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`a back surface field (BSF) layer (Okayasu, paragraph 1). A BSF layer forms a high—low
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`(HL) junction, i.e., the highly doped and lightly doped layers of the BSF have the same
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`polarity on the backside of the solar cell (Okayasu, paragraph 14) This is opposite to a
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`backside junction, whose layers have opposite polarity on the backside of the solar cell.
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`In other words, the proposed modification uses Okayasu’s teaching of forming a BSF
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`layer on the backside of the solar cell for a totally different function (i.e., to form a
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`backside junction) in Meier.
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`Third, the original structure has no tunnel dielectric, whereas the modified
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`structure has a tunnel dielectric. The Examiner’s Answer indicates that Borden (or
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`Foglietti and Gan in the other set of rejections) was used to provide motivation for
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`providing a tunnel oxide between a polysilicon layer and a monocrystalline substrate. It
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`is respectfully submitted that just because a tunnel oxide can be used between a
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`3
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`Docket No. 10031.004211
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`Reply Brief
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`polysilicon layer and a monocrystalline substrate does not mean that one of ordinary skill
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`in the art would do so for a particular structure as claimed. Here, Okayasu itself, the
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`source of the polysilicon layer in the modified structure, does not teach a tunnel oxide
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`between polysilicon and the substrate.
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`It is thus respectfully submitted that, comparing the original structure to the
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`modified structure, the rejection is based on extensive modifications that could not have
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`been made without guidance from the present application.
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`2.
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`Anti-reflective Coating On An Oxide Layer
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`Claim 1 is patentable over the combination of Meier, Okayasu, Borden, and
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`Wenham at least for reciting: “an oxide layer disposed on the front surface of the
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`substrate; an anti—reflective coating on the oxide layer.”
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`In the embodiment of claim 1, an oxide layer is disposed on the front surface of
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`the substrate, and an anti—reflective coating is on the oxide layer.
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`As explained in the appeal brief, Meier and Borden do not disclose an anti-
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`reflective coating on an oxide layer.
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`The Examiner’s Answer indicates that “Examiner finds that modified Meier
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`discloses between the polysilicon front surface field and the base substrate there is an
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`oxide layer on the front surface of the substrate (see Figure above, tunnel oxide on front
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`and back surfaces)” (Examiner’s Answer, page 13). It is respectfully submitted that the
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`Examiner’s Answer does not provide articulated reasoning on how a tunnel oxide ends up
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`on the front side of the modified structure.
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`The modified structure has an N—type polycrystalline layer and a tunnel oxide on
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`the front or light incident side of the substrate. It is respectfully submitted that there is no
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`support for this modification. In the modified structure, a polycrystalline layer is on both
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`sides of the substrate, with a tunnel oxide on both sides of the substrate. It is respectfully
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`submitted that there is no teaching or suggestion in the prior art that a polycrystalline
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`layer with a tunnel oxide can be used on both sides of the substrate, or whether such as
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`solar cell structure would even work or would have practical efficiency given that the
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`Docket No. 1003100421]
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`Reply Brief
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`polycrystalline layer and the tunnel oxide would have to receive and allow light to pass
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`through on the front side (i.e., light incident side).
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`Therefore, it is respectfully submitted that claim 1 is patentable over the
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`combination of Meier, Okayasu, Borden, and Wenham.
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`Claims 2-4 are patentable over the combination of Meier, Okayasu, Borden, and
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`Wenham at least for depending from claim 1.
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`Claim 9 is patentable over the combination of Meier, Okayasu, Borden, and
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`Wenham at least for reciting: “an emitter over the back surface of the substrate, the
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`emitter forming a backside junction with the substrate; a first dielectric between the
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`emitter and the back surface.”
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`As explained, it is respectfully submitted that the combination of Meier, Okayasu,
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`Borden, and Wenham does not teach or suggest a backside junction emitter and a first
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`dielectric between the backside junction emitter and the back surface of the substrate.
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`Claim 9 is further patentable over the combination of Meier, Okayasu, Borden,
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`and Wenham at least for reciting: “a second dielectric on the front surface of the substrate;
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`an anti-reflective coating on the second dielectric.”
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`As explained, it is respectfully submitted that the combination of Meier, Okayasu,
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`Borden, and Wenham does not teach or suggest an anti-reflective coating that is formed
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`on a dielectric on the front surface of the substrate.
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`Claims 10-12 are patentable over the combination of Meier, Okayasu, Borden,
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`and Wenham at least for depending from claim 9.
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`B.
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`CLAIMS 1-4, 7, 9—12, and 14
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`Claims 1-4, 7, 9—12, and 14 are rejected under pre-AIA 35 U.S.C. §103(a) as
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`being unpatentable over Meier (US 6,262,359), in View of Okayasu (JP 07-106611), in
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`View of Foglietti (US 2002/0142500), in View of Gan (Polysilz'con Emittersfor Silicon
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`Concentrator Solar Cells), and further in View of Wenham (US 6,429,037). The
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`rejection is respectfully traversed.
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`Docket No. 10031.004211
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`Reply Brief
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`The Examiner’s Answer provides substantially the same reasoning for this set of
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`rejection. Appellant accordingly replies as provided above.
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`C.
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`CONCLUSION
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`For at least the above reasons, allowance of the pending claims is respectfully
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`requested.
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`Dated. MM 11018
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`“Rina flea—own
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`Respectfully submitted,
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`Patrick D. Benedicto, Reg. No. 40,909
`Okamoto & Benedicto LLP
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`PO. Box 641330
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`San Jose, CA 95164
`Tel: (408)436-2110
`Fax.: (408)436-2114
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