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| Text,Aggressive Level (1-10) | |
| "Claim 1 recites ""a light shielding film that is disposed between the pad and the alignment mark."" While Takazawa914 discloses elements 15/P32/P41, these elements constitute a complex multi-layer structure rather than a single light shielding film as claimed. The reference's teaching of multiple layers arranged in a specific configuration differs from the claimed single film structure.",1 | |
| "Takazawa teaches a complex multi-layer structure (15/P32/P41) rather than the claimed ""light shielding film."" The reference's teaching at paragraphs [0073-0090] and Figure 3b shows a significantly more complex arrangement involving multiple layers with different functionalities. | |
| Furthermore, Takazawa's focus on a complex multi-layer structure actually teaches away from the simpler, more elegant solution claimed in the present application. One skilled in the art, reading Takazawa, would be led toward implementing increasingly complex multi-layer arrangements rather than the claimed single film solution.",2 | |
| "Takazawa914 discloses a complex multi-layer structure (15/P32/P41) that fundamentally differs from the claimed single ""light shielding film."" This multi-layer arrangement requires specific manufacturing steps and layer interactions that are neither contemplated nor suggested by the present claims. | |
| Further, the light shielding functionality in Takazawa914 relies on the combined effects of multiple layers working in concert. In contrast, the claimed single light shielding film provides direct and efficient light blocking between the pad and alignment mark. Furthermore, The claimed single film configuration offers significant manufacturing advantages over Takazawa914's complex multi-layer structure. ",3 | |
| "The applicant respectfully submits that independent claim 1 has been amended to include features of dependent claim 13. | |
| ""wherein a processing circuit processing the generated image signal is disposed in the second semiconductor substrate."" The Examiner cites Saito paragraph [0091] and Figure 1 for teaching this limitation. However, Saito's teaching regarding processing circuit placement is overly broad and lacks specific implementation details. Paragraph [0091] merely provides a general discussion of circuit arrangements without addressing:Specific positioning within the second substrate, Signal path optimization, Integration considerations with other components. The combination of Takazawa and Saito fails to teach or suggest the specific arrangement claimed. Moreover, the Examiner's stated motivation to combine (""to take advantage of vertical integration"") is conclusory and lacks specific technical reasoning to support the combination.",4 | |
| "Takazawa914 merely describes the alignment mark 14 disposed below an interlayer oxide film 18, and the light-shielding portion 15 is formed on the underlayer side of alignment mark 14.However, Takazawa914 does not describe a second alignment mark 14 between a pad and the light-shielding portion 15. Accordingly, the prior art Takazawa914 does not anticipate the features of “a first alignment mark on a back surface side of the first semiconductor substrate; a light shielding film between the first pad and the first alignment mark; and a second alignment mark between the first pad and the light shielding film” as recited in amended independent claim 1.",8 |