As far as I know (I travel frequently) no LION batteries can be in luggage at all. All electronic devices *must* be part of the carry on for the traveler even if your carry on has to be gate checked because of a “full flight”. You have to physically carry on your person, or carry on, all LION devices now.
They even warn you repeatedly on flights on now if you drop your phone or whatever to call an attendant because if you shift your seat you could crush your device and start a LION fire.
EDIT – if your bag is forced to be checked because you’re cheap, you have to physically carry your device, you cannot check a carry-on laptop into the hold, You’re just stuck holding it now. Along with any iPads, etc.
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