A semiconductor device and method of manufacturing the same are provided. In one embodiment, method includes forming a first oxide layer over a substrate, forming a silicon-rich, oxygen-rich, oxynitride layer on the first oxide layer, forming a silicon-rich, nitrogen-rich, and oxygen-lean nitride layer over the oxynitride layer, and forming a second oxide layer on the nitride layer. Generally, the nitride layer includes a majority of charge traps distributed in the oxynitride layer and the nitride layer. Optionally, the method further includes forming a middle oxide layer between the oxynitride layer and the nitride layer. Other embodiments are also described.