`
`Planet Depos
`
`We Make It Happen”
`
`Transcript of Martin C. Peckerar,
`Ph.D. (Volume 3)
`
`Date: September10, 2021
`Case: PEAG LLC,et al -~ 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. 1042, p. 1
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`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,
`
`VARTA MICROBATTERY GMBH,
`
`Patent Owner.
`
`Case IPR2020-01211
`
`Case IPR2020-01212
`
`USP 9,496,581
`
`USP 9,153,835
`
`Case IPR2020-01213
`
`Case IPR2020-01214
`
`USP 9,799,858
`
`USP 9,799,913
`
`Reported by: Monique Vouthouris, CCR, RPR, CRR
`
`VIDEOTAPED DEPOSITION OF MARTIN C. PECKERAR, PH.D.
`
`VOLUME 3
`
`Conducted Virtually
`
`Friday, September 10, 2021
`
`8:56 a.m. EDT
`
`Job No.:
`
`395274
`
`Pages: 351 - 445
`
`
`
`20
`
`21
`
`22
`
`JLab/Cambridge, Exh. 1042, p. 2
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`PECKERAR, PH.D., pursuant
`
`to notice, before Monique
`
`Vouthouris, CCR, RPR, CRR, Notary Public in and for
`
`the States of New Jersey and New York.
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`Conducted on September 10, 2021
`
`352
`
`REMOTE VIDEOTAPED deposition of MARTIN Cc.
`
`
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 3
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Conducted on September 10, 2021
`
`353
`
` ARANCES
`
`ON BEHALF OF PETITIONER PEAG LLC,
`
`AUDIO PARTNERSHIP LLC and AUDIO PARTNERSHIP PLC:
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`BAKER BOTTS LLP
`
`BY:
`
`NICK PALMIERI, ESQ.
`
`PAUL A. RAGUSA, ESQ.
`
`30 Rockefeller Plaza
`
`New York, New York
`
`10112
`
`212.408.2500
`
`ON BEHALF OF PATENT OWNER,
`
`VARTA MICROBATTERY GMBH:
`
`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
`
`
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 4
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Conducted on September 10, 2021
`
`354
`
`ALSO PRESENT:
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`JEAN-LOUIS ZIESCH, Planet Depos Videographer
`
`
`SARAH LOILER, Planet Depos Technician
`
`
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p.5
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`Conducted on September 10, 2021
`
`355
`
`CONT]
`
`EXAMINATION OF MARTIN C. PECKERAR, PH.D.
`
`By Mr. Palmieri
`
`By Mr. Mueller
`
`Martin C. Peckerar, Ph.D.
`
`
`
`EXHIBITS
`
`(Attached to transcript.)
`
`DEPOSITION EXHIBIT
`
`Exhibit 1005
`
`U.S. Patent Application
`
`Pub. No. US 2005/0233212,
`
`Kaun.
`
`Exhibit 1039
`
`Publication of Unexamined
`
`Patent Application (A), Kannou.
`
`Exhibit 1040
`
`U.S. Patent Application,
`
`Pub. No. US 2007/0218356,
`
`Kawamura.
`
` Exhibit 2050
`
`Supplemental Declaration of
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 6
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Conducted on September 10, 2021
`
`356
`
`
`
`
`
`
`
`
`THE VIDEOGRAPHER: This is the beginning of
`
`Media Number 1, Volume Number 3 of the continuation of
`
`the videotaped deposition of Dr. Martin Peckerar,
`
`in
`
`the matter of PEAG LLC, et al., versus VARTA
`
`Microbattery, et al.,
`
`in the U.S. Patent and Trademark
`
`Office, Case Number
`
`
`IPR 2020-01211,
`
`-12,
`
`-13, and 14.
`
`Today's date is Friday, September the 10th,
`
`2021.
`
`The time on the video monitor is 8:56 a.m.
`
`Eastern Standard Time.
`
`The certified videographer
`
`today is Jean-Louis Ziesch representing Planet Depos.
`
`This video deposition is taking place remotely.
`
`Would counsel please identify yourself and
`
`state whom you represent.
`
`MR. PALMIERI:
`
`On behalf of the petitioners
`
`PEAG LLC, Audio Partnership LLC and Audio Partnership
`
`PLC, my name is Nick Palmieri, with Baker Botts. Here
`
`with me is Paul Ragusa, also with Baker Botts.
`
`MR. MUELLER: This is Wes Mueller from
`
`
`
`
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
`
`Leydig Voit & Mayer in Chicago, on behalf of the
`
`patent owner VARTA Microbattery GmbH.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 7
`JLab/Cambridge v. Varta, 2020-01212
`
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`Conducted on September 10, 2021
`
`357
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`
`
`THE VIDEOGRAPHER:
`
`
`
`The court reporter today
`
`is Monique Vouthouris representing Planet Depos.
`
`Would the court reporter please swear in the witness.
`
`MARTIN C. PECKERAR, PH.D.,
`
`being first duly sworn or affirmed by the Notary,
`
`testifies as follows:
`
`EXAMINATION
`
`BY MR. PALMIERI:
`
`QO
`
`Good morning, Dr. Peckerar.
`
`How are you
`
`doing today?
`
`A
`
`Doing well. Hopefully you are,
`
`too.
`
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`
` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
`
`Q
`
`So before we get started,
`
`I just wanted to
`
`ask is there anyone else in the room with you right
`
`now?
`
`A
`
`QO
`
`Yes. Mr. Mueller and Mr. Wittmann.
`
`So as a preliminary matter, you've prepared
`
`two declarations in this case so far.
`
`Is that
`
`correct?
`
`A
`
`Q
`
`Yes,
`
`there are two transcripts here.
`
`Well,
`
`
`so the transcripts I believe are
`
`referring to previous depositions. But for the IPRs
`
`at issue, you prepared two expert declarations?
`
`
`
`O08:
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 8
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Conducted on September 10, 2021
`
`358
`
`A
`
`QO
`
`Yes.
`
`Just for ease of reference, I'll refer to
`
`your most recent declaration as either your
`
`supplemental declaration or your declaration since
`
`that's the primary topic of this == this deposition.
`
`A
`
`Q
`
`Yes.
`
`If I refer to the first declaration at all,
`
`I'll refer to it as your original declaration.
`
`A
`
`Q
`
`Yes.
`
`And you prepared this supplemental
`
`declaration on behalf of the patent owner VARTA.
`
`Is
`
`O08:
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`58
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`
`18
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`this declaration?
`
`A
`
`Well,
`
`I didn't type it up or put it in
`
`format.
`
`I supplied all the technical content,
`
`outlined the figures and even modified the figures
`
`with color, yeah.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p.9
`JLab/Cambridge v. Varta, 2020-01212
`
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`
`
`that correct?
`
`A
`
`QO
`
`That's correct.
`
`And you -- did you prepare the entire
`
`supplemental declaration?
`
`A
`
`Q
`
`Yes.
`
`Did you have any assistance in preparing
`
`
`
`Conducted on September 10, 2021
`
`359
`
`And so -- who provided this assistance to
`
`A
`
`Well,
`
`that was done by Leydig.
`
`They have a
`
`drafting office.
`
`Q
`
`But you prepared the substantive content of
`
`each section. That's correct?
`
`A
`
`Q
`
`Yes.
`
`And in preparing this declaration, did you
`
`review any particular materials?
`
`A
`
`Yes, of course, and those are listed in one
`
`of the sections of my -- of my supplemental report.
`
`O08:
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`1‘
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`Q
`
`And if == if we could bring onto the screen,
`
`I circulated a copy of the supplemental declaration.
`
`And on pages 1 and 2 of that declaration, you list the
`
`materials that you considered?
`
`A
`
`Q
`
`Yes, Section III.
`
`Section III,
`
`that's right. And did you
`
`review any other materials not listed in that section?
`
`A
`
`Those are the materials that I spent most
`
`time on and they're --
`
`THE TECHNICIAN: Mr. Palmieri, would you
`
`like this marked as an exhibit?
`
`
`
`09:
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 10
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`Conducted on September 10, 2021
`
`360
`
`
`MR. PALMIERI: Yes. Could you mark it as
`
`Exhibit 2050.
`
`It should already be physically marked
`
`in the copy, but...
`
`(Exhibit 2050, Supplemental Declaration of
`
`Martin C. Peckerar, Ph.D., marked for identification.)
`
`Q
`
`Okay. And so if you used any reference or
`
`reviewed any -- any materials for this declaration
`
`for -- in any substantive manner,
`
`they will be listed
`
`in that Section III.
`
`Is that correct?
`
`A
`
`QO
`
`Yes. Yes.
`
`And before we go on, are there any errors or
`
`corrections that you're aware of in your supplemental
`
`declaration that you would like to resolve?
`
`A
`
`I have none.
`
`I don't -- it is possible that
`
`I missed a typo or two.
`
`
`
`I would apologize for that.
`
`So you were previously deposed on June 2nd
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`Is that correct?
`
`I believe that was the case.
`
`Did you review those deposition transcripts?
`
`Yes.
`
`Did you review them in anticipation for
`
`today's deposition or did you just generally review
`
`
`
`1:01
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 11
`JLab/Cambridge v. Varta, 2020-01212
`
`
`
`
`
`Conducted on September 10, 2021
`
`361
`
`Just generally reviewed them.
`
`All right. Did you discuss your deposition
`
`with anyone?
`
`After the deposition was given, yes,
`
`I did.
`
`And that was == with whom did you discuss?
`
`With Leydig counsel,
`
`to some extent.
`
`Did you discuss with anyone else?
`
`No.
`
`You did not discuss with anyone at VARTA
`
`directly.
`
`Is that correct?
`
`I met with -- with VARTA
`
`09:
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` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`to any of VARTA's positions?
`
`A
`
`No.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`JLab/Cambridge, Exh. 1042, p. 12
`JLab/Cambridge v. Varta, 2020-01212
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`A
`
`No. Well,
`
`personnel. Not
`
`in conjunction with these -- with
`
`these records and proceedings.
`
`Q
`
`So you didn't -- you did not -- just to
`
`clarify, you did not discuss your deposition
`
`transcript with any VARTA personnel?
`
`A
`
`QO
`
`No.
`
`And did you discuss whether any of your
`
`previous testimony in those depositions was contrary
`
`
`
`Conducted on September 10, 2021
`
`362
`
`Q
`
`Since your previous deposition, have you
`
`been deposed in any other matters?
`
`A
`
`@)
`
`No.
`
`And have you done anything to prepare for
`
`today's deposition specifically?
`
`A
`
`Well,
`
`I read over my supplemental report a
`
`number of times, and I -- I
`
`looked -—-
`
`looked at the
`
`materials that were referenced therein. That would be
`
`the extent of my preparation.
`
`Q
`
`So in addition to the supplemental
`
`declaration, you reviewed other -- other relevant
`
`09:
`
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`materials that might have been cited therein?
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`A
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`Well,
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`the supplemental
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`included a number
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`of -- of references that were not
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`in the original
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`deposition. But
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`I believe those were all pretty
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`well-documented and listed in the supplemental.
`
`Q
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`But you didn't -- you didn't refer,
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`in
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`preparation for today,
`
`to any materials that are
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`outside of your supplemental declaration?
`
`No.
`
`Okay. And did you prepare with anyone?
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`Most of the work that I did, of course,
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`Conducted on September 10, 2021
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`363
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`was -- was my own reading and review of all
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`the supplemental and the cited materials in
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`supplemental.
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`I did have some conversation
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`with Leydig.
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`Q
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`And do you know when you met with VARTA's
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`counsel?
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`A
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`I would have to go back to my hours log.
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`don't have that with me.
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`QO
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`Do you have an approximate period of time
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`that you met with them?
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`A
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`Well, yeah,
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`I would -- well, certainly
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` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
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`idea?
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`A
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`I would say maybe three or four times.
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`As
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`I
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`said, I'd have to look at my hours log.
`
`I'm not sure.
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`between == between the deposition in June and today
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`there have been a couple of conversations, yeah.
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`QO
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`But
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`in preparation specifically for this
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`deposition have you met with them?
`
`A
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`Well,
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`I certainly met with them before this
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`deposition and we discussed issues relating to it.
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`Q
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`Okay. And do you know about how -- at least
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`how many times you've met with them,
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`just a rough
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`JLab/Cambridge, Exh. 1042, p. 14
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`Conducted on September 10, 2021
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`364
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`I don't believe that this was part of the -- of the
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`materials considered section.
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`Q
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`So in terms of your supplemental
`
`declaration -- yeah, supplemental declaration itself,
`
`I'd like to turn to what is marked as page 7 of
`
`Exhibit 2050, and that begins Section 5.A.1.
`
`In this
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`section you discuss -- you discuss dendrite growth.
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`Is that correct?
`
`Yes.
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`Do you recall that?
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`Yes. Yes.
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` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
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`So can you describe in your words how
`
`dendrites form?
`
`A
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`Yes, okay. Dendrites are little trees,
`
`okay.
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`They shoot up from -- from the negative
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`terminal plates of a battery.
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`Just about any battery,
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`by the way. And in the case of a lithium battery,
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`the
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`problem is that lithium intercalates into the cathode;
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`in other words, it inserts itself into little passages
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`in the -- in the storage material that constitute the
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`cathode. And sometimes that -- that insertion process
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`lags the arrival rate of the -- of various ions,
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`like
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`JLab/Cambridge, Exh. 1042, p. 15
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`
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`Conducted on September 10, 2021
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`365
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`a lithium ion. And as a result,
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`a tree grows up
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`because the material beneath it can't absorb it.
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`It's
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`a lot like macular degeneration, but we won't get into
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`that.
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`The == and so there are two requisites for
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`the -- for the tree-forming site.
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`The region in which
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`the tree grows has to be particularly attractive to
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`the ion in solution, and that ion has to be
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`incident -- what we call a -- it's called a nucleating
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`site, and the tree will grow up from the nucleating
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`site, which is triggered by a reduction in free energy
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`of the ion itself. And so you get these tree=-like
`
`structures shooting up.
`
`Would you like some more? Let me also say,
`
`I mean,
`
`in secondary cells, dendrite formation is a
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`major problem in just about every cell that you can
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`imagine.
`
`I did a lot of work in trying to develop
`
`rechargeable zinc batteries. We had a hell of a time
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`with dendrites in rechargeable zinc.
`
`Q
`
`So following up on that, can you describe --
`
`and maybe I just missed this a little -- where the
`
`dendrite formation begins at.
`
`So we have -=— and,
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`
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`JLab/Cambridge, Exh. 1042, p. 16
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`Conducted on September 10, 2021
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`366
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`actually,
`
`let me clarify that a little more.
`
`So let's
`
`say we have an electrode layer and a separator layer
`
`and a second electrode layer.
`
`Can you describe where
`
`in that configuration the dendrite formation would
`
`begin?
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`
`
`MR. MUELLER: Objection to form.
`
`A
`
`Well, let's see here. Okay.
`
`It will form
`
`in what we call nucleating sites, areas where the ion
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`motion is impeded and is more likely to plate, and
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`that -- and there could be secondary considerations as
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`well.
`
`I mean, let's suppose that -- of course, all of
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`the separated materials that we discuss are either
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`woven, meaning that they have fibers across one
`
`another which leave pores,
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`the nucleation might occur
`
`within a pore, and it might be assisted by a kind of
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`scaffolding that a separator represents. And that
`
`will be true in other ionic separators,
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`like Nafion or
`
`other materials as well.
`
`So,
`
`so does that answer your question, if
`
`you'd like?
`
`QO
`
`A
`
`That helps.
`
`I have some follow-ups on it.
`
`Okay.
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`JLab/Cambridge, Exh. 1042, p. 17
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`367
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`Q
`
`So can -- can these nucleating sites be
`
`found on the electrode layers as opposed to the
`
`separator materials?
`
`A
`
`Q
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`Yeah,
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`they can pretty well
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`form anywhere,
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`And so is the separator material usually
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
`
`
`
`chosen to reduce dendrite formation?
`
`MR. MUELLER: Objection to form.
`
`A
`
`Well, you do what you can to get rid of the
`
`dendrites, okay.
`
`You use surface treatments, you
`
`choose the separator materials.
`
`In the barer areas,
`
`I
`
`mean,
`
`that was relatively easy to address because in
`
`the barer areas you generally see -- see structures
`
`forming which we call mounds. Maybe I'm getting ahead
`
`of my report, but you have to remember I taught this
`
`stuff for a long time so you'll excuse me for waxing
`
`poetic.
`
`We use brightener additives to plating mast
`
`to avoid mounding, and the -- and so there were a
`
`number of approaches that you would use to eliminate
`
`dendrite formation.
`
`Q
`
`So I want
`
`to look at a specific example and
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`PLANET DEPOS
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`368
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`so this will be the Kaun reference, which you discuss
`
`throughout your report.
`
`It's Exhibit 1041 in these
`
`IPRs. We can stay on the same Exhibit 2050 as well,
`
`that's all right.
`
`So, Dr. Peckerar,
`
`in Kaun we have a specific
`
`example of a spiral wound electrode assembly, with a
`
`separator located in between the electrode layers.
`
`Is
`
`that correct?
`
`A
`
`Yes.
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`MR. MUELLER: Objection to form.
`
`QO
`
`And one of the topics of discussion for that
`
`reference is the formation of gaps between the
`
`separator materials.
`
`Do you recall that?
`
`MR. MUELLER: Objection to form.
`
`Yes,
`
`
`I recall that discussion.
`
`And so bringing -- bringing the dendrites
`
`A
`
`@)
`
`back in, would dendrites form in the electrode
`
`assembly of Kaun?
`
`MR. MUELLER: Objection to form.
`
`A
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`As
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`
`I just testified, dendrites can form
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`wherever. Nucleating sites develop and nucleating
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`sites can develop pretty much anywhere.
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`369
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`Q
`
`So the nucleating sites could form on the
`
`electrode layers of Kaun?
`
`MR. MUELLER: Objection to form.
`
`A
`
`Q
`
`And in the separators as well. Anywhere.
`
`So could they form in the gap between the
`
`separator layers?
`
`MR. MUELLER: Objection to form.
`
`A
`
`As
`
`
`I said,
`
`
`I do have a section on this in my
`
`supplemental report, but let me say yes,
`
`they could
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`form in those regions.
`
`QO
`
`And if they form in the gap regions, would
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`there be anything to inhibit their growth?
`
`
`MR. MUELLER: Objection to form.
`
`A
`
`What would inhibit their growth would be the
`
`rate of arrival of the -- of the ion that constitutes
`
`the dendrite, and -- and what that arrival rate is
`
`depends on a number of things. And I wouldn't say
`
`that there's any reason to believe that that arrival
`
`rate or the density of nucleating sites would be
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`different in either the gap or in the region over
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`the -- beneath the separator.
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`In fact, as I mentioned earlier,
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`there's
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`reason to believe that the separator might serve as a
`
`scaffolding that support the growth of the tree.
`
`Q
`
`So does the separator then form to --
`
`apologies,
`
`let me rephrase that.
`
`Does the separator then act to inhibit the
`
`growth of dendrites so that they cannot
`
`form a
`
`connection between the electrode layers?
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
`
`MR. MUELLER: Objection to form.
`
`There's no reason to believe that.
`
`So it's your testimony that the separator
`
`A
`
`Q
`
`does not inhibit --
`
`A
`
`It could actually <= it could actually speed
`
`it up, but you'd have to -- there's a tremendous
`
`amount of literature on this.
`
`I believe we've
`
`
`included some of that in our -- I've included that in
`
`my report and -- but as I said, you can get little
`
`trees forming anywhere.
`
`Q
`
`And so you have another section here, and
`
`it's on pages 8
`
`to 9 of Exhibit 2050,
`
`that describes
`
`the use of a polyvinylidene fluoride, also known as
`
`Kynar,
`
`that's described in the Kaun reference.
`
`A
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`Right.
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`JLab/Cambridge, Exh. 1042, p. 21
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`Q
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`Can you -- can you describe what this Kynar
`
`is doing? And apologies if I'm saying that wrong.
`
`I'm happy to take a corrected pronunciation if you
`
`have it.
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume3)
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`A
`
`Yeah, no, it is Kynar.
`
`I believe he
`
`pronounces his name Kaun.
`
`If -- if the butt joint is too large, of
`
`course there's a danger that you could -- there are
`
`certain deleterious effects that could occur, but --
`
`and so if you're worried about that, according to
`
`Kaun, you can put Kynar, which is a resin, an
`
`insulating resin, and solve the problem.
`
`Q
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`And this Kynar would prevent dendrite
`
`formation?
`
`A
`
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`I think that that -- I don't -=- that
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`certainly wouldn't eliminate the dendrite problem, no.
`
`But it -- it would prevent
`
`
`the formation of other
`
`types of deleterious effects, and I believe that was
`
`the main issue.
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`Q
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`So you've noted a couple times the -- the
`
`effects that can be caused from a gap forming. Could
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`you describe some of those deleterious effects?
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`JLab/Cambridge, Exh. 1042, p. 22
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`A
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`Obviously you've got a separator, right, and
`
`on top of and on bottom under the active electrodes.
`
`And if you've got this huge gap, when you squeeze
`
`things together, you short the electrodes out.
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`Also, we make a big deal == okay. We make a
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`big deal about particle sizes, okay. We choose the
`
`particle sizes to be large enough in the active
`
`material so that -- just large enough so that they
`
`won't penetrate the separator material themselves and
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`also they wouldn't fall into any -- to create shorts
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`in themselves.
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`So we -- so we -- as a matter of fact,
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`in
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`one of my companies we had a very expensive particle
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`size sorter and we would choose specific particle
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`sizes that wouldn't crash through the separator and at
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`the same token wouldn't fill up the pores of the
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`materials that we were using.
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`They would be -=-
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`they
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`wouldn't be too small,
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`they wouldn't be too big;
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`they'd be just right. But these are all the
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`considerations that go into battery manufacturing.
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`So those are some of the issues;
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`there will
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`be shorting out of the layer and what all, which I
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`JLab/Cambridge, Exh. 1042, p. 23
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`think would be rare, even in Kaun's case.
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`Or
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`the
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`particles which would pierce the layer for -- well,
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`those are the main issues,
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`so that would outline.
`
`@)
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`And so -- so going back to this Kynar
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`material, if we assume that it's being used as an
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`adhesive to fill that gap, what differentiates it from
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`the separator material?
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`MR. MUELLER: Objection to form.
`
`A
`
`Well, Kynar is non-conductive resin.
`
`Now,
`
`the separator materials -- as I've testified
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`
`
` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
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`previously,
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`the separator materials are highly
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`engineered structures and they're aimed at passing
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`ions of a certain type.
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`Now, clearly the Kynar isn't
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`an engineered material that was designed to do that.
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`So it might
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`lead to some effective area reduction of
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`the battery plate. Not a lot.
`
`Q
`
`A
`
`A
`
`QO
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`So the ==
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`Small amount.
`
`(Court Reporter clarification.)
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`Not a lot, small amount.
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`So the Kynar doesn't facilitate ionic
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`conduction the way that the separator material does?
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`PLANET DEPOS
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`JLab/Cambridge, Exh. 1042, p. 24
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`374
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`A
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`QO
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`No.
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`So you have to have some sort of separator
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`material in there in order for the battery to
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`function?
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`MR. MUELLER: Objection to form.
`
`A
`
`Well,
`
`I mean, Kaun cites that as one
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`possible remedy to some imagined problem.
`
`He didn't
`
`specifically cite the problem that he was addressing
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`here, but it was just something he threw over the
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`wall.
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`QO
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`Okay.
`
`So now moving on into Section 5Bl,
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`:00
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` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`I got it.
`
`Page 9 of the -- on the PDF.
`
`Okay. Yeah,
`
`
`I got it in my documents.
`
`Okay, yeah.
`
`Sorry for the delay.
`
`Q
`
`No problem at all.
`
`So this section
`
`which begins on page 12 of Exhibit 2050,
`
`this == this
`
`section discusses the central fastener of Kaun.
`
`
`
`that correct?
`
`Excuse me, what was the page?
`
`Sorry.
`
`So it's page 12 of 43 on the
`
`A
`
`@)
`
`exhibit.
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`
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`JLab/Cambridge, Exh. 1042, p. 25
`JLab/Cambridge v. Varta, 2020-01212
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`Conducted on September 10, 2021
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`375
`
`discusses the central fastener of Kaun.
`
`
`
`correct?
`
`A
`
`QO
`
`Yes.
`
`And you reproduce on the next page,
`
`you reproduce a number of figures from Kaun.
`
`see those?
`
`A
`
`Q
`
`Yes.
`
`If we're looking only at Figure 7A,
`
`central fastener shown in that figure?
`
`A
`
`QO
`
`No.
`
`And then moving on to Figure 7C, do
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` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`MR. PALMIERI: And, Sarah, could we bring
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`PLANET DEPOS
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`JLab/Cambridge, Exh. 1042, p. 26
`JLab/Cambridge v. Varta, 2020-01212
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`
`figures show == does Figure 7C show a central
`
`fastener?
`
`A
`
`Q
`
`Yes and yes.
`
`And if we could move into Kaun itself, and
`
`that's Exhibit -- apologies,
`
`I don't remember
`
`the
`
`exact exhibit number for Kaun.
`
`Sorry,
`
`just one
`
`second.
`
`So Kaun is Exhibit 1005 of these IPR
`
`proceedings.
`
`A
`
`Yes.
`
`
`
`Conducted on September 10, 2021
`
`376
`
`that up as well on the screen.
`
`THE TECHNICIAN:
`
`Is that the document ending
`
`in U.S. 2005/0233212?
`
`MR. PALMIERI: That's correct, yeah. Yes,
`
`starts with K-a-euen. Great.
`
`Thank you.
`
`(Exhibit 1005, U.S. Patent Application Pub.
`
`No. US 2005/0233212, Kaun, marked for identification.
`
`
`
`BY MR. PALMIER
`
`QO
`
`So I want
`
`to look at paragraph 69 of 0069,
`
`which corresponds with those figures that we were just
`
`looking at,
`
`7A through 7D.
`
`You just passed it.
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` Transcript of Martin C. Peckerar, Ph.D. (Volume 3)
`
`A
`
`Q
`
`Is that the one you're referring to?
`
`Yeah.
`
`So those are the figures, and then if
`
`we can go to paragraph 0069 on this specific language.
`
`THE TECHNICIAN:
`
`I'm sorry,
`
`I'm not entirely
`
`sure where to go.
`
`
`MR. PALMIERI:
`
`Sorry.
`
`So within Kaun, if
`
`you could go to page -- page 15 of the PDF, and on
`
`that page is paragraph 69, on the left there, yeah.
`
`A
`
`Q
`
`It should be on page 4 -- page 15 of this
`
`PDF, overall?
`
`
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`PLANET DEPOS
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`JLab/Cambridge, Exh. 1042, p. 27
`JLab/Cambridge v. Varta, 2020-01212
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`
`
`Conducted on September 10, 2021
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`377
`
`Perfect.
`
`Thanks.
`
`QO
`
`Okay.
`
`So in paragraph 69 we can see there's
`
`a description of Figure 7C that says it "depicts the
`
`outer pan of the housing for the electrochemical
`
`device,
`
`including the central
`
`[sic] fastener,
`
`polymeric tube."
`
`Do y
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