A multiple memory layer device has a plurality of stacked memory layers. Each of the memory layers has: a charge generating layer of p-type semiconductor material with a plurality of n-type diffusion regions; an insulating layer disposed over the charge generating layer; a charge storing layer disposed over the insulating layer; and another insulating layer disposed over the charge storing layer. A gate is disposed over the top insulting layer in the uppermost memory layer in the plurality of stacked memory layers.