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The only time my player ever gets warm from using the harddrive is when it's plugged into a PC and doing a full restore (all 40gb) or defragment (not really needed when the file have all been restored from the PC in one go because there's virtually no fragmentation).
It probably gets warmer sitting in your jeans pocket than it would in a case of any type because the harddrive is hardly accessed when playing files normally.
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