From what I've gathered from around the internet is that it's often phones/ipods that have been enclosed in restrictive covers/cases that have become too hot. The recommended advise was to remove the phone/ipod from the case when using it for extended periods (especially when using processor-intensive applications). Primarily though it's those phones that have been "jailbroken" (ie cracked to use different networks) and therefore may run hotter than the software would normally allow.
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