You're forgetting about Apple's own apps! Mail and Safari DO NOT actually close down and free up memory when you exit to the home screen. That has proven to be the cause of 98% of my memory issues. Try it yourself... do not reboot the phone next time you can replicate the low-memory warning... instead open Safari and force-quit it by *holding* the home button for 6-8 seconds (until Safari finally disappears). Do the same thing for Mail. Now try your app again... you probably (as in I'd place bets!) wont have a memory warning after that.
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