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I've used a 2210 and the back speaker doesn't really bother me much. Yeah, if you happen to cover it with your hand, the sound may be muddled a bit. But at the same time, let's keep in mind that most PDA speakers are far from hi-fi. I find that it's not really a big deal and that the sounds that matter are still quite audible.
If you're going to be listening to music, or doing something which requires the maximum level of sound quality possible, it will probably be through headphones anyway.
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