In some sense though, I imagine that when you hear something in a foreign language, you are actively making links to sounds or words that you think it may relate to (so in some sense, taking a mental note).

Growing up, I found that listening attentively in class and asking questions had me retain the most. Overly focusing on note-taking actually distracted me and those would usually be my worse day. I still took notes, however, most of the learning happened in the classroom and my notebook was the "textbook" that acted as my reference later.

However for taking notes I still prefer paper. It's really small aesthetic things like the texture of the paper and the no-latency ink. For some reason although taking notes with the digital pen results in better notes the experience of taking the notes is less pleasing to me.

Like I said I optimize for the best note-taking rather than taking the best notes. Once or twice when I was bored, I intentionally created illegible notes by writing in scribbles, or writing over a full sheet as if it was a new sheet.

Even creating illegible notes produced a learning outcome, and in some cases I felt the information stuck more because those notes were different and stimulating.

The only time I use paper is when I don't have the iPad on me and for personal journaling (for which I have a dedicated notebook anyway).