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Never happened to me, but most of the time I go back to the homescreen before I put the reader to sleep (at least if I plan to actually stop reading instead of just answering the phone or something). The T1 only saves the current position once you exit the book, so if you read 500 pages without going back to home and the reader app crashes you'll start at 1 again. I've also read about e-pubs that can drain the battery pretty fast if you leave the book open and put the reader to sleep.
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