Paul Venezia wonders the same thing I did when I first read reports about over-heating.

I’ve read that some folks first noticed the problem when they kept the phone under their pillow (why you would do this kinda escapes me, but OK)  … My iPhone 3GS: Not So Hot – PC World.

Of course none of this stopped me from ordering the new Iphone 3GS.  When it gets here, and if It overheats, It will be under warranty and I’ll take it back.  And if they issue a recall, I’m fine w/ that.