It might just be a firmware bug. I don't use notes myself so I haven't come across it. I do however recall there being a bug about notes not being saved properly if you don't exit the note in a specific way. I think it was the difference between hitting the "X" and hitting "Done" or something. I'm sorry I can't check right now as my device isn't with me. If you search this forum you might find the bug in question.
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