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I’ve got a headboard bed for this exact reason. Back in the age of paper books I was able to hold paperbacks quite comfortably and hardcovers by resting them on my torso. As with an ereader the trick is to make sure your elbows are well supported on the matress.
Thinking back to how heavy some of the bigger hardcover books were and how I had to put then on the matress and lie on the side to read them, I find holding and reading on ereaders and even my tablet in bed, very easy.
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