`
`Transcript of Dr. Hans Jurgen
`Lindner
`
`Date: June 8, 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. 1037, p. 1
`JLab/Cambridge v. Varta, 2020-01212
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`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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` I N D E X
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`WITNESS EXAMINATION
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`
`DR. HANS JÜRGEN LINDNER
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` By Mr. Palmieri...........................6
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` By Mr. Hartmann.........................120
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`NUMBER DESCRIPTION PAGE
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`1001- United States Patent
`IPR2020-01212 US 9,153,835 B2................67
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`1001- United States Patent
`IPR2020-01213 US 9,799,858 B2................78
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`1005 United States Patent
` Application Publication
` US 2005/0233212 A1 (Kaun)......96
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`1007 European Patent Specification
` EP 1 886 364 B1 (Ryou)........107
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`1008 Korean Patent Application
` (Kwon)........................114
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`2046 Declaration of Dr. Lindner.....18
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`PEAG LLC (d/b/a JLab Audio), AUDIO PARTNERSHIP LLC
`and AUDIO PARTNERSHIP PLC (d/b/a Cambridge Audio),
`
` Petitioner,
`
` v.
`
` VARTA MICROBATTERY GMBH,
`
` Patent Owner.
`
`
` Case IPR2020-01211 Case IPR2020-01212
` USP 9,496,581 UPS 9,153,835
`
` Case IPR2020-01213 Case IPR2020-01214
` USP 9,799,858 USP 9,799,913
`
`
`
` VIDEOTAPED DEPOSITION OF:
`
` DR. HANS JÜRGEN LINDNER
`
`
`
` TRANSCRIPT OF TESTIMONY, as reported by
`
`Nancy C. Bendish, Certified Court Reporter, RMR,
`
`CRR and Notary Public of the States of New York
`
`and New Jersey, conducted virtually via Zoom
`
`Videoconference on Tuesday, June 8, 2021,
`
`commencing at 8:08 a.m. EST.
`
`
`
` THE VIDEOGRAPHER: Here begins
`recording number 1 in the videotaped deposition
`of Dr. Hans Jürgen Lindner, in the matter of
`PEAG LLC et al. versus VARTA Microbattery GmbH,
`held in the United States Patent and Trademark
`Office held before the Patent Trial and Appeal
`Board.
` Today's date is June 8th, 2021.
`The time on the video monitor is 8:09 a.m.
`Eastern US time. The videographer today is RJ
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`Buckler CLVS representing Planet Depos. This
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`deposition is taking place remotely via Zoom.
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` Would counsel please introduce
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`themselves and state whom they represent.
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` MR. PALMIERI: My name is Nick
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`Palmieri with Baker Botts representing the
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`petitioners. Also here with me is Paul Ragusa,
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`also with Baker Botts.
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` MR. HARTMANN: I'm Mike Hartmann
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`for patent owner in all four of the IPRs that I
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`believe this deposition is being taken in.
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` THE VIDEOGRAPHER: The court
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`1234567891
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`A P P E A R A N C E S:
`
`(All participated remotely via
` Zoom Videoconference)
`
`
`ON BEHALF OF PETITIONER, PEAG LLC, AUDIO
`PARTNERSHIP LLC and AUDIO PARTNERSHIP PLC:
`
`
` BAKER BOTTS LLP
` BY: NICK PALMIERI, ESQ.
` PAUL A. RAGUSA, ESQ.
` 30 Rockefeller Plaza
` New York, New York 10112
` 212.408.2500
` nick.palmieri@bakerbotts.com
` paul.ragusa@bakerbotts.com
`
`
`ON BEHALF OF PATENT OWNER,
`VARTA MICROBATTERY GMBH:
`
`
` LEYDIG VOIT & MAYER, LTD.
` BY: H. MICHAEL HARTMANN, ESQ.
` WESLEY O. MUELLER, ESQ.
` Two Prudential Plaza
` 180 N. Stetson Avenue, Suite 4900
` Chicago, Illinois 60601
` 312.616.5600
` mhartmann@leydig.com
` wmueller@leydig.com
`
`
`ALSO PRESENT:
`
` VINCENT ZHANG, Baker Botts
` DANIEL WENG, VARTA Microbattery
` LILY OLM, German Translator
` JARED BENNETT, Planet Depos Technician
` RJ BUCKLER, Planet Depos Videographer
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`JLab/Cambridge, Exh. 1037, p. 2
`JLab/Cambridge v. Varta, 2020-01212
`
`

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`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
`5
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`2 (5 to 8)
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`you. If at any time you need me to clarify a
`question, repeat a question, just let me know.
`Also, please feel free to use our interpreter if
`you need any question interpreted into German.
`And otherwise I will assume that you understand
`the question that I ask. Feel free to ask for
`clarification on anything.
` A. That's okay with me.
` Q. Throughout this deposition I'll
`refer to the patent owner VARTA Microbattery
`GmbH as "VARTA." Are you all right with that?
` A. Yes.
` Q. Before we begin as well, is there
`any information in your declaration that you
`would like to correct or any errors that you
`would like to fix?
` A. The document is okay with me.
`There is no problem with it.
` Q. Okay. And just to clarify, the
`declaration you submitted is in English,
`correct?
` A. Yeah, of course, yeah.
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`reporter today is Nancy Bendish representing
`Planet Depos. Would the reporter please swear
`in the witness.
` - - -
`LILY OLM, German Translator, was remotely sworn
`by the Court Reporter.
`D R. H A N S J Ü R G E N L I N D N E R,
` having been remotely sworn by the
` Court Reporter, testified as follows:
` THE REPORTER: Please state your
`full name.
` THE WITNESS: Hans Jürgen Lindner.
` THE REPORTER: And the address
`where you are presently located.
` THE WITNESS: I live in Germany in
`the City of Herne, and I live on the floor of a
`house on Eickeler Strasse 24. That's the street
`where I'm living.
` THE REPORTER: And where are you
`presently located in this moment?
` THE WITNESS: Now I'm in the
`factory of VARTA Microbattery here in Ellwangen.
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`EXAMINATION BY MR. PALMIERI:
` Q. Thank you, Dr. Lindner, for taking
`time to speak with us today. We just have some
`initial questions we wanted to ask before we get
`into it.
` First, is there anyone else in the
`room with you right now?
` A. Yeah, I have somebody with me in
`the room, yeah.
` Q. Okay. Can you state their name.
` A. Dr. Lindner, I'm the former
`development engineer and the quality manager for
`VARTA when I was still working.
` Q. And the name of the person in the
`room with you?
` A. That's Rainer Jostes, one of my
`colleagues.
` Q. And he's the only other person in
`the room with you?
` A. Yes.
` Q. And so we're going to generally
`proceed in English, if that's all right with
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` Q. You didn't prepare a German
`language version of this document?
` A. I did not what?
` Q. Prepare a German -- sorry.
` (Question translated.)
` A. Partly, partly. I prepared it in
`German and I prepared it also partly in English.
` Q. Okay. But the document submitted
`is all in English and you're comfortable
`proceeding in English?
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` A. Yes, correct.
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` Q. Great, thank you. And you're not
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`a lawyer, correct?
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` A. I'm not a lawyer. I'm a chemist.
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` Q. You don't have any background
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`education in US patent law specifically?
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` A. No, I don't have any background on
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`that one.
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` Q. Okay.
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` A. (Indiscernible.)
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` (Reporter clarification.)
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` A. I have no background in legal
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`PLANET DEPOS
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`JLab/Cambridge, Exh. 1037, p. 3
`JLab/Cambridge v. Varta, 2020-01212
`
`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
`9
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`battery development and manufacturing, correct?
` A. Yes.
` Q. And you haven't been involved in
`any of the sales or commercialization of VARTA's
`batteries?
` A. No. If they have a question, I
`can help them in sales, but the sales department
`have to take over. I'm not directly involved
`with customers in that time.
` Q. Okay. So have you ever directly
`communicated with customers, in particular in
`connection with the CoinPower batteries?
` A. No, I did not.
` Q. And have you been involved with
`the development of any other products at VARTA
`beyond CoinPower batteries?
` A. Yes.
` Q. Can you describe what those
`products were?
` A. Very simple, when I started with
`VARTA in '88, 1988, I was in the development
`department of nickel-cadmium round cells,
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`skills in USA.
` Q. And have you ever been deposed
`before?
` A. I have never been what?
` Q. Deposed.
` A. No. No, it's okay. I did not
`understood the word "deposed." No, I have never
`been deposed at all.
` Q. And have you ever testified at a
`trial or other similar proceeding?
` A. No, not here in Germany, not
`anywhere else in the world.
` Q. And what did you do in preparation
`for today's deposition?
` A. I was just reading my deposition
`and the patents, what we discuss today probably,
`and I think also some other literature which
`were in the name for the various prior art
`documents, which I get.
` Q. And did you speak with anyone else
`at VARTA specifically?
` A. No, only with my colleagues like
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`Michael Hartmann and Dr. Jostes.
` Q. And did Dr. Jostes speak with you
`about this deposition in advance of today?
` A. I don't think so, no. I see
`Rainer for the first time this week.
` Q. And did you speak with Dr. Martin
`Peckerar in advance of today?
` A. No, not recently, no.
` Q. When's the last time you did speak
`with Dr. Peckerar?
` A. It was already weeks ago. Was
`probably around beginning of May.
` Q. And what did you discuss with him
`at the beginning of May?
` A. I think your sound line is very
`bad. I don't get your -- what did you ask?
` Q. What did you speak with Dr.
`Peckerar with at the beginning of May?
` A. That was about the various patents
`we hold and what was about the technology he
`invented and I think that was more or less all.
` Q. So your background is primarily
`
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`cylindrical round cells, and consumer batteries
`during that time. And I have also been
`responsible for running the pilot line on
`nickel-metal hydride round cells, which are --
` (Reporter clarification.)
` A. Nickel-metal hydride. That's a
`subsequent system like the nickel-cadmium
`batteries that was giving us more capacity and
`that was development, what we did.
` Q. And were those cylindrical
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` A. Yes. They were all in -- that was
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`a different place of manufacturing and that was
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`nickel-cadmium batteries also for the airplanes
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`and all other systems what we supported --
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` (Reporter clarification.)
`16
` A. I have to recall the sentence.
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` It was at that time when I was
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`responsible for the development and also for the
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`production, and then I was working on all those
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`systems which we had in that factory that were
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`round cells for consumer, for OEM customers and
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`JLab/Cambridge, Exh. 1037, p. 4
`JLab/Cambridge v. Varta, 2020-01212
`
`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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`for military goods.
` Q. And you used the term "round
`cells" there. Is there a difference between
`that and cylindrical cells?
` A. No, the same wording actually.
` Q. And are -- would button cell
`batteries also be considered a round cell?
` A. We did not manufacture the button
`cells in that part of the factory. That was
`coming in later.
` Q. But would you classify button
`cells as a type of round cell?
` A. Can you repeat, please?
` Q. Yes. So you've referred a couple
`times to round cells.
` A. Yes.
` Q. I'm wondering if you use the term
`"round cells" to also describe button cell
`batteries?
` A. No. Definitely not for us, either
`the round cell or cylindrical cell is that the
`diameter is smaller than the height, and button
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`cells are normally the cells which are diameter
`didn't quite get that.
`bigger than the height.
` A. That was the development
` Q. And so can you also just provide a
`department in VARTA Hagen. That's a small
`brief background on your education.
`village southern of the Dortmund region.
` A. I studied chemistry at the
` Q. And you're no longer employed by
`University of Bochum and I get my diploma degree
`VARTA, correct?
`over there, what is roughly about the step
` A. I'm only -- I was not working with
`before you can do your Ph.D. actually, and then
`VARTA. Now I'm back for VARTA here helping them
`I work on the Ph.D. as well during my time.
`with this trial, yeah.
`When I came out of them, I went over to VARTA
` Q. But you retired from your --
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`Microbatteries.
` A. Yes.
`11
` Q. So you didn't work anywhere else
` Q. -- positions. Okay.
`12
`before joining VARTA?
` And could you provide a -- could
`13
` A. No. I had a small military career
`you describe what position you were in around
`14
`for the two years, compulsory service.
`the time these patents were filed?
`15
` Q. And as part of your Ph.D. did you
` A. In the beginning I was working in
`16
`prepare a dissertation or a thesis paper?
`the development department here in Arlen
`17
` A. Yes. That is the longer way we
`(phonetic) on batteries and battery development
`18
`have it in Germany, that you have to have a
`of various systems, and then I started to work
`19
`diploma degree. Then you have already special
`on this project, making a new cell, and we have
`20
`practical work to do in and supply the documents
`then been working inside the -- what is it
`21
`over there, and then you go with this one and
`called? I was working as a manager for new
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`PLANET DEPOS
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`ask professor to take you on as a doctor degree
`in future.
` So, that one is definitely a
`thesis that was, I think a couple of years I
`worked over there only; if I'm not mistaken,
`four years.
` Q. And what was the topic of your
`research during your Ph.D., during those years?
` A. At the university, that was the
`studies on phosphor chemistry which had various
`impact, for instance to what is called
`fertilizers and also for killing insects.
` Q. So, as you said, you began working
`at VARTA immediately after you finished your
`Ph.D.?
` A. Yes.
` Q. And that was in 1987?
` A. That was in '88 I started in
`December with VARTA in Germany at the factory in
`Hagen.
` Q. Can you just repeat where you
`started working, where was that location? I
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`JLab/Cambridge, Exh. 1037, p. 5
`JLab/Cambridge v. Varta, 2020-01212
`
`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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`technologies.
` Q. And what were your
`responsibilities in that position?
` A. Guiding the various people which
`belong to me and that the most important role
`that I have to guide the practical work of those
`fellows as well, and supervise them.
` Q. And before that role, you were
`working in Singapore, correct?
` A. I was working in Singapore at that
`time, yes, before I came back here.
` Q. That was around 1993 to 2007,
`approximately?
` A. I started with VARTA in Singapore
`in 1993, and I worked with them for a couple of
`years until '97.
` In '97 I left VARTA and went to
`the University of Singapore where I was asked to
`build up, what do you recall, an arm to develop
`battery systems, and then I was away from that
`one as well so I worked for a startup company
`and that's more or less -- I think I have
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`can see it, but if anyone needs me to zoom in
`further, I'm happy to do so.
` So, in paragraph 19 you note that
`during your time in Singapore the current state
`of button cell technology produced only poorly
`performing cells. Can you describe what you
`mean by poorly performing cells?
` A. That was when I have been
`responsible for the quality department in our
`manufacturing plant for battery assembly, and
`those cells we had there were from all over the
`world where you can buy them and produce
`batteries of that one.
` So, with that one we found out the
`batteries were leaking, they did not give us the
`right performance, what we wanted to have for
`the customers, and we had problems to weld them
`because of the thin walls they have over there.
`So with that one we had been working on that one
`with high yields of --
` (Reporter clarification.)
` A. -- with a new loss of output
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`because the cells were leaking, the cells were
`written it on my CV as well.
` I was working also in two
`welded through and they had (indiscernible).
`different research labs in Singapore. The one
` (Reporter clarification.)
`institute was called Materials Research and
` MR. HARTMANN: Jürgen -- if I
`Engineering, and the other one was GINTIC, that
`might break in for minute -- if you can just
`was Nanyang Technology.
`slow down speaking, I think that might be very
`helpful for our poor court reporter. She has to
` Q. And then after those you returned
`get every word and she has to get it right, or
`to working at VARTA, correct?
` A. Then I retire during that time
`she's trying her very best to get it right. So
`already for VARTA, yes. And then I came back to
`it would be helpful if you just slowed down a
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`VARTA in, I don't know, 2000 something.
`little bit.
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` THE WITNESS: Okay, I try to.
` Q. So now I'm going to share my
`12
` A. So, I try to repeat what I said.
`screen and show you a specific paragraph within
`13
` When we had poor yield during the
`your declaration. Specifically it's paragraph
`14
`welding, during the assembly of the batteries
`19. And let me know when you're able to see my
`15
`into the device or into the battery compartment,
`screen or feel free to follow along in your own
`16
`then we had the trouble and we realized we need
`copy.
`17
`to do something better.
` (Exhibit 2046 was entered into the
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` So, first of all, we need to
`record at this time.)
`19
`support our beliefs in the factory floor to use
` A. I can see your screen, yes.
`20
`the cells that are really very well manufactured
` Q. Great, great. And I'll try to
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`make sure the text is large enough that everyone
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`JLab/Cambridge, Exh. 1037, p. 6
`JLab/Cambridge v. Varta, 2020-01212
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`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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` Q. Okay. So there were several types
`of cells produced at --
` A. Oh yeah, oh yeah. A huge number.
` Q. And so specifically for button
`cells you were using resistance welding and
`noticed these issues?
` A. Exactly, yeah, because available
`machine and it was key and we could make it in
`Indonesia with all of the problems. At that
`time the laser welding machines were not so
`sophisticated as they are today.
` Q. And so could you just describe
`what the process of resistance welding would
`look like for a button cell?
` A. Come again, what?
` Q. So could you describe the
`resistance welding and the process of resistance
`welding specifically.
` A. Okay. So what we have is to weld
`a contact to the cup or the lid to the flat part
`of the cell actually. And with that one with
`these two electrodes, then you contact the tag
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` Q. And so you know that there was
`poor yield during welding specifically.
` A. Yes.
` Q. What about the welding process
`caused this poor yield?
` A. We welded electrical contacts to
`the cells so to bring out the currents to the
`device. So with that one we needed to do
`resistance welding over there and we had big
`problems of the welding through. That means the
`resistance welding is very hot, and so we made
`holes into the separator material, we made holes
`into the electrode materials, which then
`subsequently made short circuits inside the
`cells.
` Q. So these issues were -- were they
`specific to resistance welding?
` A. That was our preferred method in
`that kind of system. We had also some laser
`welding, but that was not used for this battery
`which we have assembled over there.
` Q. For those cells where you used
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`laser welding, did you ever notice the same
`issues arise?
` A. No. That was for the CR2016, the
`very thin one, lithium primary, and with that
`one we did not have any problems when we
`adjusted the energy right, then we had good
`yields on welding. If we used them or that
`cell, for instance, resistance welding, then we
`had big problem with the separator material
`because the hot welding step with this
`resistance welding were melting the lithium and
`the lithium then penetrated the separator
`material to make the short circuit.
` Q. And so you used this on -- were
`these button cells that both of these techniques
`were used on, or other types of cells?
` A. I was there in Singapore in the
`battery assembly factory. I was quality man, so
`we had on the table cylindrical cells, we had
`prismatic cell types, we had button cells from
`all technologies which were available at that
`time.
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`by a little bit up further, and then you release
`the welding energy. With that one you weld to
`the contact and to the housing and made a very
`tough contact.
` Q. And so what causes the weld bead
`to be formed there?
` A. That was --
` MR. HARTMANN: Let me object to
`the question. I don't understand the question.
`So I'm going to object to the form of the
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` MR. PALMIERI: I can reword.
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` Q. So does the weld bead originate at
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`the point of contact between the two parts being
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`welded?
`17
` A. Yes. You can see the two
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`energy on the contact, and if you break this one
`20
`away from the cell can call it, then you should
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`see also that the energy went through to the
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`JLab/Cambridge, Exh. 1037, p. 7
`JLab/Cambridge v. Varta, 2020-01212
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`

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`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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`developing these cells?
` A. I have to admit I don't know
`anything about that one, because that is the
`customer relation with the people from sales.
`They should bring us then the information what
`did the customer need.
` Q. So no one -- did anyone from sales
`bring to your attention a desire by customers
`for more active devices, for batteries that
`could be used in more active devices?
` A. I have not been involved in that
`one, but I know that the customers sometimes
`came with the sales and marketing people to
`visit our factory in Indonesia, yes.
` Q. And did any customers ever visit
`your factory in Singapore?
` A. In Singapore at that time we did
`not have anymore manufacturing office or
`manufacturing plant. It was only a sales office
`and the, what do you call it, the (German words)
`office.
` (Reporter clarification.)
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`housing part. So that was one of the major
`qualities that's to prove that you have done a
`good welding.
` Q. So the energy goes through the
`housing itself?
` A. Yes, sure. What you use normally,
`what we call it, a Y-tag. So you have the Y-tag
`going to the surface and then you have the
`electrode one to the one arm of the Y and the
`other electrode to the second arm of the Y. And
`then you release under pressure the energy and
`then you have a point of current to the cup or
`the lid.
` Q. And in resistance welding would
`the weld bead pass all the way through the
`housing?
` A. I did not get your question.
` Q. I can repeat.
` In resistance welding, does the
`weld bead pass all the way through the housing?
` A. Normally not. The welding is done
`to the housing only over the tag and therefore
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`then you have a current flowing and then coming
`out of the other end. Where you have the higher
`areas of resistance, then you have the weld
`bead.
` Q. And that higher area of resistance
`is the interface between -- apologies, scratch
`that.
` A. Yes, correct, yes, yes.
` Q. Let me repeat.
` The highest area of resistance is
`where the materials being welded meet?
` A. Yes.
` Q. I'd like to turn to paragraph 20
`in your declaration. I just want to note a
`statement that you made.
` So you state that existing
`batteries were fine for relatively passive
`watches, but not for more active devices that
`draw higher currents, and you cite the Bluetooth
`earphones and medical applications.
` Were you aware of customers making
`use of those technologies at the time you were
`
` A. The office was -- we did not have
`anymore a manufacturing place in Singapore. We
`had only an office for the sales and the
`marketing people, plus the legal people which we
`needed for running our factories in Batam.
` Q. And so before working -- well,
`before developing these batteries, the batteries
`at issue here, you noted you did work on
`cylindrical cell batteries?
` A. Yes.
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` Q. Did you ever work on capacitors?
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` A. No. Capacitor was never an item
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`for us.
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` Q. So you never worked on producing
`14
`any capacitors through your work with VARTA?
`15
` A. No. I'm only a battery man and
`16
`that's for all the reason of my life, my working
`17
`life, yes.
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` Q. Now, did you ever look at
`19
`capacitors for these others in the course of
`20
`your work?
`21
` A. Not that I know of. We have never
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`JLab/Cambridge, Exh. 1037, p. 8
`JLab/Cambridge v. Varta, 2020-01212
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`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
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`seen a capacitor in our factory for reverse
`engineering, all that, have a good idea what
`comes out of that one. That was not in my task.
` Q. Okay. So you personally never
`looked at other capacitors to try to bring in
`art from them?
` A. No, no.
` Q. I want to ask about, so we've been
`using the term "button cell" pretty regularly
`throughout and you use it throughout your
`declaration. But VARTA's batteries, the VARTA
`batteries you allege are covered by the patents
`here, are called CoinPower batteries. Now, are
`those -- can you describe a difference between a
`button cell and a coin cell battery?
` A. No. For me the CoinPower -- let's
`say the coin cell and the button cell is the
`same. As long as the diameter is bigger than
`the height, then it's a coin or a button cell.
`So for me as somebody who was working in the
`field, the same words for the same issue.
` Q. Okay. So there's -- the two terms
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`subdivision on that one. It's all used as
`priming for cells which are having the same
`feature, small limited capacity and the height
`is smaller than the diameter.
` Q. Okay. Before we move on, are you
`receiving any compensation from VARTA in return
`for your testimony?
` A. I have highlighted that one in my
`deposition. Then you see that I get for the
`time being as I work on this project, together
`with VARTA people, a monthly salary about 2,000
`euros.
` Q. Okay. And do you receive any
`other payments from VARTA related to these
`patents?
` A. Related to the patents, I do know
`from the German law for inventors, if that is
`coming to a commercial issue, then I get a
`certain kind of fee back of the sales turnover.
` Q. And are those -- sorry. Is that
`payment related to sales in Germany itself or
`are those worldwide sales?
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` A. It's depending on the production
`volume and the sales volume, will be
`incorporated -- don't ask me how it is really
`calculated, I don't know it. I'm always happy
`to get the check.
` Q. And so you note that it's an
`average of around 11 -- 1,143 euros a year.
` A. Yes.
` Q. And that's for all patents on
`which you're named inventor, or is that value
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`only for the patents here?
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` A. It's only for the patents we are
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`having here in mind about the CoinPower.
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` Q. So you receive -- do you receive
`14
`any other payments for other patents?
`15
` A. Not really. I think those were a
`16
`long time ago. They are already, what is it
`17
`called, end of life for the patent fee.
`18
` Q. Okay. And so you get those
`19
`payments because you're a named inventor for the
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` A. I hope I get them because I was
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`are interchangeable to you?
` A. From my point of view it is -- you
`can use the same, the both words for the same
`issue, yes.
` Q. And in several parts of your
`declaration -- I'm going to point to paragraph
`27 here -- you reference a microcell. Is a
`microcell different than a button cell?
` A. From my point of view, it's also
`the same. It's only describing that the cell is
`small in height and big in diameter, and micro
`means they have limited power source for any
`application.
` Q. So would you describe a microcell
`as a subset of button cells?
` A. I did not get you.
` Q. So would you describe a microcell
`as a subset of button cells?
` A. No, I don't get the English word.
`What does it mean? We need the translator.
` (Question translated.)
` A. No, we are definitely not a
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`JLab/Cambridge, Exh. 1037, p. 9
`JLab/Cambridge v. Varta, 2020-01212
`
`

`

`Transcript of Dr. Hans Jurgen Lindner
`Conducted on June 8, 2021
`33
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`to use a different technology than inside the
`cylindrical cells or inside the nickel-cadmium
`batteries.
` So that is definitely something
`where we needed a lot of trials and error to
`make good cells over there.
` Q. And so can you describe the
`challenges in reducing the size like that?
` A. You see when the diameter is
`getting bigger and bigger and the cell height is
`getting lower and lower, I have no force to grip
`those three parts, the electrode positive,
`electrode negative, and separator material.
` So then you have to use some other
`type. The winding has to be slow and it has to
`be really, how to say, accurate. Then it's --
`to make a wind. Otherwise the whole cell stack
`of that one, if you do the winding, the cell
`stack will fall out.
` Q. And moving into paragraph 23 of
`your declaration, you note the different kinds
`of commercial button cells at the time. And in
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`the inventor.
` Q. Okay. Now, I think we'll move on
`a litt