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Whether an ereader is more comfortable to hold with or without a cover is going to depend on the design of the e-reader, the size of the hand and how the person prefers to hold the reader (side? Bottom? Other?)
And I agree that if I'm using an ereader while sitting on my couch or lying in bed the risk is low.
Another factor that usually doesn't get mentioned in these discussions about whether to use a case is budget. For some people an ereader is major expense and if it breaks they will have to save up for a new one. For other people the cost of replacing an ereader is negligible (if wasteful). Everyone has their own personal calculation of comfort vs risk.
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