`
`Transcript of Martin C. Peckerar,
`Ph.D.
`
`Date: June 2, 2021
`Case: PEAG LLC, et al -v- VARTA Microbattery GMBH. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`JLab/Cambridge, Exh. 1034, p. 1
`JLab/Cambridge v. Varta, 2020-01212
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`

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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
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` I N D E X
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`WITNESS EXAMINATION
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`MARTIN C. PECKERAR, Ph.D.
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` By Mr. Ragusa............................7
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` E X H I B I T S
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`NUMBER DESCRIPTION PAGE
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`1001- United States Patent
`IPR2020-01211 US 9,496,581 B2................83
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`1001- United States Patent
`IPR2020-01212 US 9,153,835 B2................83
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`1001- United States Patent
`IPR2020-01213 US 9,799,858 B2................83
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`1001- United States Patent
`IPR2020-01214 US 9,799,913 B2................83
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`1005 United States Patent
` Application Publication
` US 2005/0233212 A1............131
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
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`PEAG LLC (d/b/a JLab Audio), AUDIO PARTNERSHIP LLC
`and AUDIO PARTNERSHIP PLC (d/b/a Cambridge Audio),
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` Petitioner,
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` v.
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` VARTA MICROBATTERY GMBH,
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` Patent Owner.
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` Case IPR2020-01211 Case IPR2020-01212
` USP 9,496,581 UPS 9,153,835
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` Case IPR2020-01213 Case IPR2020-01214
` USP 9,799,858 USP 9,799,913
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`
` VIDEOTAPED DEPOSITION OF:
`
` MARTIN C. PECKERAR, Ph.D.
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`
`
` TRANSCRIPT OF TESTIMONY, as reported
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`by Nancy C. Bendish, Certified Court Reporter,
`
`RMR, CRR and Notary Public of the States of
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`New York and New Jersey, conducted virtually via
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`Zoom Videoconference on Wednesday, June 2, 2021,
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`commencing at 9:12 a.m. EST.
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` E X H I B I T S (Cont'd)
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`NUMBER DESCRIPTION PAGE
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`1006 Japanese Patent Office
` Publication No.JP 2007-294111....179
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`1031 Curriculum Vitae of Martin
` Peckerar, Ph.D....................13
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`2043 Corrected Declaration of
` Martin C. Peckerar, Ph.D..........67
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`A P P E A R A N C E S:
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` (All participated remotely via
` Zoom Videoconference)
`
`
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`ON BEHALF OF PETITIONER, PEAG LLC, AUDIO
`PARTNERSHIP LLC and AUDIO PARTNERSHIP PLC:
`
`
` BAKER BOTTS LLP
` BY: PAUL A. RAGUSA, ESQ.
` NICK PALMIERI, ESQ.
` 30 Rockefeller Plaza
` New York, New York 10112
` 212.408.2500
` paul.ragusa@bakerbotts.com
` nick.palmieri@bakerbotts.com
`
`
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`ON BEHALF OF PATENT OWNER,
`VARTA MICROBATTERY GMBH:
`
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` LEYDIG VOIT & MAYER, LTD.
` BY: WESLEY O. MUELLER, ESQ.
` ROBERT T. WITTMANN, ESQ.
` Two Prudential Plaza
` 180 N. Stetson Avenue, Suite 4900
` Chicago, Illinois 60601
` 312.616.5600
` wmueller@leydig.com
` bwittmann@leydig.com
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`ALSO PRESENT:
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` DANIEL TERRY, Planet Depos Technician
` BRENDAN CASE, Planet Depos Videographer
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`PLANET DEPOS
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`JLab/Cambridge, Exh. 1034, p. 2
`JLab/Cambridge v. Varta, 2020-01212
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`

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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
`5
` THE VIDEOGRAPHER: Here begins the
`video deposition of Dr. Martin Peckerar in the
`matter of PEAG, LLC, et al., versus VARTA
`Microbattery GmbH, held in the United States
`Patent and Trademark Office, Cause Number
`IPR2020-01211; 12, 13 and 14.
` Today's date is Wednesday,
`June 2nd, 2021. The time is 9:12 a.m., Eastern
`Standard Time.
` Your videographer of the day is
`Brendan Case, representing Planet Depos.
`This deposition is taking place via video
`teleconference via zoom.
` Would counsel present please
`identify themselves and whom they represent.
` MR. RAGUSA: Paul Ragusa and
`Nicholas Palmieri of Baker Botts on behalf of
`the petitioners, PEAG, LLC, and Audio
`Partnership, LLC.
` MR. MUELLER: Wesley Mueller from
`Leydig Voit & Mayer, representing the patent
`owner, VARTA Microbattery GmbH. And with me is
`6
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`2 (5 to 8)
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`Maryland University.
` THE REPORTER: Okay. Thank you.
` You may begin.
` MR. RAGUSA: Okay. Terrific.
`EXAMINATION BY MR. RAGUSA:
` Q. Good morning, Dr. Peckerar.
` A. Good morning.
` Q. Have you been deposed before,
`either in reality or in virtual form?
` A. Never virtually, but in reality,
`yes, a number of times.
` Q. How many times?
` A. I believe the number is five.
` Q. And were those all patent cases?
` A. Yes.
` Q. Were any of those cases involving
`VARTA?
` A. Could you repeat that, please.
`Involving?
` Q. Sure. Did any of those cases
`involve VARTA?
` A. Can you hear me?
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`Bob Wittmann.
` THE VIDEOGRAPHER: The court
`reporter today is Nancy Bendish, representing
`Planet Depos.
` Would the court reporter please
`swear in the witness.
`
` M
`
` Q. We can hear you fine, yes.
` A. Involving VARTA? No, never
`involving VARTA.
` Q. Did any of those cases involve
`batteries?
` A. I did an IPR; I provided input to
`Finnegan on their part in an IPR associated with
`Milwaukee Power and the battery associated with
` A R T I N C. P E C K E R A R, Ph.D.,
`their power tools.
` having been remotely sworn by the
` Court Reporter, testified as follows:
` Q. What time frame was that?
`0
` A. I think that was five years ago,
` THE REPORTER: Your full name,
`11
`five to seven years ago. I mean, I'm relying on
`please.
`12
`my memory here.
` THE WITNESS: Martin Charles
`13
`Peckerar.
` Q. Understood.
`14
` THE REPORTER: Thank you.
` Have you given testimony at trial
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` And your address where you're
`before?
`16
` A. Yes.
`presently located, at least the city and state.
`17
` THE WITNESS: The address of the
` Q. And can you describe the case that
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`recording site or my home address?
`that occurred in?
`19
` A. Yeah, I went before the ITC twice.
` THE REPORTER: Where you are
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`One was a lawsuit involving the DDR3 bus control
`presently.
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`spec for almost every laptop that's used in the
` THE WITNESS: Okay. College Park,
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`JLab/Cambridge, Exh. 1034, p. 3
`JLab/Cambridge v. Varta, 2020-01212
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`

`

`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
`9
`world. And then I helped to defend Macronix in
`an issue associated with memory technology,
`nonvolatile memory technology.
` Q. So you have some background in the
`procedure. Let me just give a quick refresher.
` I'll ask some questions today.
`Obviously, if you don't understand a question,
`please let me know, and I'll do my best to
`rephrase the question. Obviously we need to
`work together on that. Unless you tell me
`otherwise, I'll assume --
` A. Yes.
` Q. -- that you do understand the
`question. Can we proceed with that
`understanding?
` A. (Witness nods.)
` Q. Okay. And --
` A. Yes.
` Q. -- for the court reporter's sake
`if you could say yes or no. I know it's -- we
`all like to nod our heads, but that would be
`appreciated as well. Thank you.
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`age in particular; hence why I ask it.
` Is there any information that
`you're aware of in your declaration that is
`subject to correction or that you feel needs to
`be corrected, sitting here right now?
` A. There were a few typos. It is a
`270-page report, and when I -- I missed a few on
`correction, but the sense of the issue is
`present in the document and was easily
`recognizable, so nothing affecting the
`interpretation.
` Q. Okay. Thank you.
` Let's turn to your educational
`background. And I have your updated CV, which
`I'll share for the court reporter. I understand
`that this is a new CV that was not the CV in the
`IPR, so let's give it a new exhibit number.
` The next available IPR exhibit
`number is 2047.
` MR. MUELLER: Counsel, sorry to
`interrupt, but if it's an exhibit number that
`the petitioners are using, it should probably
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`3 (9 to 12)
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` Today I'll refer to the patent
`owner VARTA Microbattery as "VARTA"; if that's
`okay with you?
` A. (Witness nods.)
` Q. Again, if you could just say yes.
` A. Yes.
` Q. Okay, terrific.
` Before we begin --
` A. Can you not hear me?
` Q. There's just a slight delay, so,
`yes, we do hear you.
` A. Okay. I think you may have to
`wait a second to hear the response, right.
` Q. Correct. So before we begin --
` A. Your light isn't what it used to
`be.
` Q. No, it's not.
` Before we begin, is there any --
`any reason why you can't testify today, either
`medical -- medically or otherwise?
` A. No. No.
` Q. Good question to ask in today's
`
`have a 1000 number.
` MR. RAGUSA: Okay. Let's change
`that. Nick, if you could just quickly look that
`up.
` Q. While we're getting the exhibit
`number right, why don't we turn to your
`educational background.
` Is it correct that you have a
`bachelor's in physics from Stony Brook, 1968?
` A. Yes.
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` Q. A master's in physics from the
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`University of Maryland?
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` A. Yes.
`13
` Q. And finally a Ph.D. in electrical
`14
`engineering?
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` A. Yes.
`16
` Q. Okay. Can you tell me the topic
`17
`of your Ph.D. thesis?
`18
` A. Yes. Surface anodization of
`19
`electronic materials using semiconductive
`20
`technology.
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` Q. Did your educational training
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`JLab/Cambridge, Exh. 1034, p. 4
`JLab/Cambridge v. Varta, 2020-01212
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`

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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
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`circuits that were powered by batteries but not
`the batteries themselves; is that correct?
` A. (Witness nods.)
` Q. Okay. And let's turn to --
` A. Not at that point in my career.
` Q. Let's turn to your next position.
`Was that at the Naval Research Laboratory?
` A. Naval Research Laboratory, yes.
` Q. And did your work at the Naval
`Research Laboratory involve --
` A. Yes.
` Q. -- the construction of batteries?
` A. No. It involved analytic
`chemistry, largely for detecting pollutants in
`the environment.
` Q. Okay. If we turn -- and I'm
`sorry. The -- looks like you had two periods
`where you worked at the Naval Research
`Laboratory, one from --
` A. Right.
` Q. -- 1973 to '76 and the second from
`'81 to 2002?
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`involve the construction of batteries?
` A. Of course. I took courses that
`taught -- my leanings were toward
`electrochemistry, and so I did take courses in
`that. But I don't have any specific degrees in
`chemistry, no, or battery technology, but I have
`worked extensively in the battery arena.
` Q. Okay. So, focusing on the -- on
`your educational time period, did you take
`courses in the construction of battery housings?
` A. Not specifically. That's a rather
`specific topic that is rarely covered in
`course -- academic course work.
` Q. Understood.
` A. As a teacher, I can tell you that.
` Q. Okay. Understood.
` MR. RAGUSA: And I've been
`informed that this exhibit should be
`Exhibit 1031.
` (Exhibit 1031 marked for
`identification.)
` Q. So, turning to your employment
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`history, what was your first position after
`receiving your Ph.D. back in 1975?
` A. I went to work for Westinghouse
`Electric as a process development engineer.
` Q. And did that work entail working
`with batteries?
` A. It involved fabrication of
`electronic parts. Of course, in -- even at that
`time, back in the '60s, we had a very integrated
`approach to development in chip design and
`production. And so of course the power supplies
`are important in how those -- that power is
`supplied to a chip, which I believe has
`relevance to the battery area. So I did work in
`that area in that regard.
` Q. Okay. Did your work involve the
`construction of batteries?
` A. Involved the construction of
`integrated circuit components, chips, which
`interfaced or were powered by batteries.
` Q. Understood.
` So you worked on the integrated
`
` A. Right. And in the interim, I
`worked at Westinghouse about five years, yes.
` Q. Okay. Terrific.
` Overlapping that time period, you
`were a professor at the University of Maryland;
`is that correct?
` A. Yes. After my Ph.D. my thesis
`advisor hired me to become adjunct and then part
`time, yes.
` Q. And did the courses that you
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`include courses involving the construction of
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`batteries?
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` A. They -- of course even in junior
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`electronics we talked about batteries, and I
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`taught the essential design and characterization
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`of battery technology. That was always a part
`17
`of the courses that I taught, yeah.
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` Q. Okay. But did that coursework
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`involve --
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` A. Yeah, I don't know --
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` Q. -- building batteries?
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`JLab/Cambridge, Exh. 1034, p. 5
`JLab/Cambridge v. Varta, 2020-01212
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`

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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
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` A. No.
` Q. What was the area of your research
`during that time period?
` A. Well, I ran the microelectronic
`processing facility, and so in that regard, I
`developed tools and technologies for the
`construction of electronic material and
`components.
` Q. What was system on a chip tool
`sets?
` A. Oh. That involved the integration
`of diverse materials. For example, normally --
`normally, of course, chips are made out of
`silicon, but in a system on a chip, one has many
`more components than is usually envisioned in a
`microchip.
` In other words, we might include
`elements that would be used as sensors. We
`might include elements that might be used to
`generate power in one form or another, such as
`photovoltaics and even batteries, you know,
`microbatteries that could be integrated.
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`5 (17 to 20)
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`believe we actually won the SAIC award for
`innovation back in 2008 or 2009. So I was
`working in the battery development area, both in
`my role as a professor and as an academic
`advisor and subsequently into company
`development.
` Q. Let's pin down that time period in
`a moment. According to your CV, you won an
`award in 2013, right? An Entrepreneur of the
`Year award. Do you recall that?
` A. That was the entrepreneur, right.
`That was a state university system award. There
`was one before that.
` Q. What was the subject matter for
`that award?
` A. We were developing something,
`which we called a baticitor, which actually
`played into some of the work that we're going to
`be talking about today. It was a combination of
`a supercapacitor and a battery.
` And what's more, that baticitor
`was flexible, and so it can be used in wearable
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` The idea is that the chip is --
`electronics. And I would say the -- probably
`could be -- the notion of a chip could be
`over the last 11 or 12 years, that type of
`extended from a silicon-based component into
`component development has been my major research
`a -- into a system that perform multiple
`and actual hands-on development focus.
`functions beyond that which is normally
` Q. Do you still have that award?
`envisioned, and that involved new material
` A. Yes. It's on my wall. And we can
`developments and integration.
`go down to my office. I can show it to you, if
` Q. And did any of that work
`you like.
`specifically address the construction of
` Q. Okay. I simply want to verify
`batteries?
`that the year was 2013.
`0
` A. Not at this point. Although, I
` A. Yes.
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`think from 2008-2009, as we'll see in the next
` Q. And if we could verify that, that
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`would be great.
`13
`hands-on battery fabrication and development.
` A. Well, that one, I think you're
`14
` Q. Okay. Let's turn to that. So
`referring to the --
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`your CV lists work experience from 2012 to
` MR. MUELLER: Counsel, he was
`16
`present involving two small businesses, FlexE,
`still talking.
`17
`LLC being the first, correct?
` A. Yeah. I think you were referring
`18
` A. FlexEl.
`to the University of Maryland state system
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` Q. FlexEl.
`award. As I said, I'd been working in the
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` A. FlexEl, right. And I believe --
`technology well before that, and there were
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`you know, I'm looking at this timeline, and I
`other awards. In particular, there was one from
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`JLab/Cambridge, Exh. 1034, p. 6
`JLab/Cambridge v. Varta, 2020-01212
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`

`

`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
`21
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`skill looking to build a battery be motivated to
`look at technology related to capacitors when
`seeking to make modifications to batteries?
` MR. MUELLER: Objection to form.
` A. Of course all of the components
`that we've been discussing, all the way up to
`integrated circuit technology, make use of
`chemical and physical processing means. And so
`in that regard, there's some relation. But of
`course the basic physical principle of
`operation, the capacitor is different than the
`physical operation of a battery. So there are
`similarities and differences.
` Q. And specifically regarding
`housing, would somebody of ordinary skill in the
`art be motivated to look to capacitor housings
`for solutions in developing battery housings?
` MR. MUELLER: Objection to form.
` A. Without becoming overly
`professorial here, okay, the -- if you're -- the
`essence of the insertion of a capacitor
`technology as an energy storage device has
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`SAIC on a novel device development.
` Q. Okay. Let's turn to that.
` MR. RAGUSA: And apologies,
`Mr. Mueller. I didn't realize that I had even
`interrupted him. I was adjusting my headset.
` Q. Dr. Peckerar, if we could turn,
`I'm sorry, to the other award you were talking
`about. When was that award given, and do you
`recall its title?
` A. I think it was before 2010.
`That's my recollection.
` Q. And what was its title?
` A. To the best of my recollection, it
`was -- I'm trying to think. It was the Best
`University Invention, something to that effect.
` Q. Would you have a record of that
`award in your office as well?
` A. Yes.
` Q. Okay. And so we'll put in a
`request for a photograph or something else to
`memorialize the date of that award.
` A. Okay.
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` Q. So, speaking of batteries and
`supercapacitors, what relationship, if any, is
`there between batteries and capacitors?
` A. A capacitor stores energy; a
`battery supplies energy through electrochemical
`means. It actually creates energy by chemical
`reaction.
` Q. Are the two related technologies?
` A. Yeah. Much of the same technology
`is used in both cases, but there are, of course,
`subtle differences.
` Q. Understood, and we'll certainly
`turn to that.
` How is your work history relating
`to capacitors relevant to your expertise in this
`case, if at all?
` A. Well, supercapacitors are devices
`that involve many of the same materials. The
`metal current-collecting plates, the
`electrolytes which support the formation of
`what's called double-layer charge.
` Q. And would a person of ordinary
`
`different endpoint goals and different
`requirements than that of a battery.
` For example, a capacitor has to
`supply energy rapidly to surroundings. It has a
`very fast discharge profile, while that is
`certainly not the case with a battery. So you'd
`be aiming for different things, one -- with
`respect to one another.
` So you couldn't just say, well, if
`I made a battery housing or if I made a device
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`aimed at a battery requirement, could I -- would
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`I glean some information from capacitor housing.
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`Well, since the goals and requirements are so
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`different, it isn't certain, that's for sure.
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`It isn't certain.
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` I mean, if you look at a
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`capacitor, it might have a steel can, and
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`there'd be a similarity in that direction. But
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`of course, as I said, since there are such
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`diverse goals, I couldn't state with certainty
`20
`that that would be the case.
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` Q. Okay. We'll get into some
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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
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`specifics shortly.
` Let's return back to your work at
`FlexEl. What work did you do in connection with
`that company?
` A. I was one of the founding
`partners, and I was chief technology officer.
` Q. And did that company work on a
`nonflammable power supply for electronic
`cigarettes?
` A. Oh, yes.
` Q. And what work did you do in
`connection with that product that involved
`batteries?
` A. I tried to optimize the chemistry
`that would supply -- we had -- for flexible
`cell, we had the largest storage capacity per
`unit area of any cell on the market at the time,
`and I helped develop those chemistries. To that
`end, I -- actually, I kneaded the cathode dough.
`I helped physical assembly.
` Q. And did your work on that project
`involve the battery housing?
`
`7 (25 to 28)
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`for cheaper product; not as well -- as I recall,
`it wasn't -- it didn't perform as well.
` Q. So, did you have a view as to the
`Chinese competition being an inferior product?
` MR. MUELLER: Objection to form.
` A. I felt it didn't have the same
`capacity, but Reynolds was willing to overlook
`that.
` Q. Now, your CV refers to
`manufacturing ultrathin flexible power sources.
` A. Yes.
` Q. Is that a characterization of the
`work that you did in trying to remove the
`battery can?
` A. Yes. Exactly. Just roll the
`whole thing up. Don't worry about putting a
`steel can around it.
` Q. And just so I understand, by
`rolling the assembly up, are you referring to
`rolling electrodes with a separator up?
` A. Yes.
` Q. Is that configuration known in the
`
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` MR. MUELLER: Objection to form.
` A. Did it involve -- yeah. There
`were two camps. Okay? One camp wanted to
`create a stand-alone cell that would be
`removable and re-insertable. And another camp
`wanted to eliminate the housing and create the
`electrochemistry within the e-cigarette itself,
`without any further need for housing.
` So, I was in the latter camp. I
`didn't believe you needed a separate can. I
`felt it added weight and was -- and could be
`avoided.
` Q. And did that work end up being
`realized in a product?
` A. We provided a prototype to
`Reynolds, our sponsor in this area. But as you
`know, other e-cigarettes overtook the Reynolds
`market, and we weren't selected in the final
`call for the battery itself.
` Q. Now, your CV refers to
`ultrathin --
` A. As I recall, they went to China
`
`art as a "jelly roll"?
` A. I would label it a jelly roll,
`yes.
` Q. And did you use flexible metal
`films as being the current-collecting source for
`that jelly roll?
` MR. MUELLER: Objection to form.
` A. I used thin metal films
`throughout, both for the reactive plate, the
`anode and cathode. The reactive elements.
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` Also, the means of current
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`withdrawal from the sandwich. I would have
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`advocated, as I said, just rolling the composite
`13
`together and sticking it into the e-cigarette
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`without a steel can.
`15
` Q. Okay. You referred to means for
`16
`current withdrawal from the sandwich. And let
`17
`me -- so that I'm clear, by "the sandwich," are
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`you referring to the jelly roll?
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` A. I'm referring to the electrode
`20
`stack.
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` Q. Okay. Which is part of the jelly
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`roll?
` A. With the separator in part, which
`could be part of a jelly roll, yeah.
` Q. Okay. And --
` A. I mean, we originally made -- go
`on. Sorry.
` Q. No, no. I'm sorry. Please,
`continue your answer.
` A. Yeah. I would have termed the
`original product a pouch cell. But when we
`rolled it up, it had similarities to a jelly
`roll.
` Q. And by means for current
`withdrawal from that pouch cell or jelly roll,
`is that an output conductor?
` A. Yeah. You needed some kind of an
`output conductor, right. And in many cases in
`the past, in addition to output conductors,
`there were conducting plates that we used.
` I would argue that before we
`rolled it up, the means of current output was
`through a current collector, collecting plate.
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`because then the cell becomes -- occupies less
`volume. But, you know, countering that, the
`electrodes are the active material. They're
`kind of the fuel that makes things go. And
`so -- and so, as I recall, we settled on
`something around 4 mils, 100 microns, as I
`recall. This is all from memory.
` Q. No. Understood.
` What range of thickness would you
`consider to be a foil?
` MR. MUELLER: Objection to form.
` A. I don't think there's really -- I
`think a foil generally implies some flexibility.
`I think that's -- if you're looking for a term
`of the art, I would say it referred to
`flexibility. I don't think there's a definite
`thickness, which -- and then again -- well...
` Q. I'm sorry. Did you have more in
`your answer, or are you stopping there?
` A. I'll stop there for now. If you
`have any more questions about it, of course I'm
`more than willing to answer.
`
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`But when we rolled it up, then I referred to the
`tab as an output conductor. But, you know,
`these definitions, as I said, all require
`definition based on their instantiation.
` Q. Understood.
` So, I mean, specifically referring
`to the jelly roll-type product that you worked
`on for FlexEl, was the output conductor a metal
`foil?
` A. Yes.
` Q. And was one of the output
`conductors made out of aluminum and the other
`made out of a different metal?
` MR. MUELLER: Objection to form.
` A. Aluminum was very difficult to
`use. We largely used zinc. Other metals,
`titanium. We tried aluminum -- of course we
`tried everything.
` Q. Do you recall the thickness of the
`metal that you used for your output conductors?
` A. Yeah, of course. In one sense,
`you try to make them as thin as possible,
`
` Q. Sure.
` So would the thickness depend upon
`the type of metal that's being used for the
`output conductor?
` A. Okay. I'll finish answering.
` Yes, it would. Different metals
`have different elastic properties. If you want
`something that's highly flexible, you may say,
`well, let's work with -- you can go two routes.
`You can work with a thinner foil, if you will,
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`or you can go to a foil that can be made thicker
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`and would have -- and be more elastic and still
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`maintain flexibility.
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` Q. You also referred to output
`14
`plates. Is there a difference between an output
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`plate and an output foil?
`16
` MR. MUELLER: Objection to form.
`17
` A. Well, let me just say, the term
`18
`"plate" infers an object which has very low
`19
`flexibility. And also, if you think in terms of
`20
`common parlance, a plate would be viewed as
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`something that would extend over a large area.
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`Transcript of Martin C. Peckerar, Ph.D.
`Conducted on June 2, 2021
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`There'd be differences, yeah.
` Q. Can a film extend over a large
`area and still serve as an output conductor for
`a battery?
` MR. MUELLER: Objection to the
`form.
` A. Yeah. Well, you see, that's the
`issue. It depends on the ultimate -- that's
`what I was trying to get at before -- it depends
`on the ultimate utilization. I mean, for
`example, if -- if you had to -- if you had, say,
`a conducting rod, and you placed that -- wanted
`to have that rod contact a conducting plate, if
`that plate -- and if you subsequently had to
`insert that assembly into a complicated
`structure, you really couldn't have a foil, in
`the sense of flexibility. You'd have to have
`something that maintains some rigidity, for a
`couple of reasons.
` Q. And what are those reasons?
` A. Well, if you were trying to insert
`the assembly with this flexible, floppy top,
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`you're going to be very unsuccessful, if you try
`to draw that into the ultimate system.
` Also, if you try to make contact
`between the rod and the plate, then you'd like
`the plate to have some degree of rigidity, so
`that when you made the contact, you didn't plow
`through the foil. So that would give you some
`limits on flexibility. That would give you some
`limits on the thickness of the -- the ultimate
`thickness of the foil.
` Q. Let me turn to your other projects
`from 2012 to present. VersaVolt, can you
`describe your work in connection with that
`company.
` A. Yeah. It's largely a consulting
`company where we talk about using nonstandard
`electrochemical devices to do various types of
`analytic work. You know, as I said, wearable
`electronics.
` And in addition to the
`wearables -- actually, the cell that we made was
`activated by water, and it -- and, actually,
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`blood, blood plasma, was a sufficient
`electrolyte to derive power from what I felt
`were unique cells.
` So, we tried to sell that concept.
`And we would consult with companies to see how
`flexible electronics could be inserted.
` Q. Did the --
` A. Largely biomedical application.
` Q. Did the cell include a jelly roll
`assembly?
` A. No, those didn't. Those were
`more -- we called them electric Band-aids.
`You -- especially in a wound. Okay? What you
`would do would be place the -- this electric
`Band-aid as a dressing over the wound, and the
`blood