:WP:LEDE is a guideline, rather than a set of rules - but I see your point to some extent. The trouble is that the article is structured in such a way that criticisms such as Bardi's don't really fit in anywhere. He isn't evaluating 'the device', he is evaluating Rossi's claims regarding it. And since everything we know about the device (beyond the obvious, that it is a device which seems to take cold water in at one end, and emit hot water and/or steam at the other) is solely sourced to Rossi, Rossi is now flatly contradicting things he said earlier, and is still refusing to let anyone do any meaningful independent evaluation at all, one has to ask whether we should be implying in our article that it is the device that is now the centre of attention, rather than Rossi. Perhaps the section entitled 'Evaluation of the device' should be retitled 'Evaluation of claims regarding the device' - and expanded. Bardi has actually written about the E-Cat several times, and a little more of his sceptical take on the matter might be as good thing, per WP:FRINGE, and WP:PARITY in particular. If we can show why Bardi describes the affair as 'pathological science' in more detail, we can cover some of the issues that have had to be left out for now, as lacking WP:RS. If we do this, there seems no reason why we can't also quote Bardi in the lede, if appropriate.