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It doesn't happen every day, at least. I've noticed that if I shut the sleep cover at a slight angle, it'll be closed but not quite enough to put the device to sleep. Most likely it wakes up if I shift the cover a little bit when I set it down for the day. I usually put the device to sleep via NickelMenu at the end of the day, so the cover image is right side up when I close the sleep cover.
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