In some embodiments where the memory cell being manufactured is a resistive random memory (RRAM) cell, the data-storage element 212 may include, for example, hafnium oxide, other suitable high-κ dielectrics, or other suitable dielectrics. In some embodiments where the memory cell under manufacture is a magneto-resistive (MRAM) cell, the data-storage element 212 may include, for example, an MTJ layer or another suitable magnetic storage structure. The MTJ layer may include, for example, a first ferromagnetic layer, an insulating layer overlying the first ferromagnetic layer, and a second ferromagnetic layer overlying the insulating layer. In some embodiments where the memory cell be manufactured is an RRAM cell, the data-storage element 212 may include, for example, hafnium oxide, another suitable high-κ dielectrics, or another suitable dielectrics.