Try this to repro it: Go into Notes and make one or more voice recordings such that the total note space nearly fills program memory (or probably over 1/2). Then close that note and reopen it. I had the problem when I went to play back a recording, but missed the icon and put a little digital ink on the note. When I tried again to play back the voice recording, Note said that it did not recognize the format. Then I closed the Note and tried opening it again, but it would not open. I checked the memory, and nearly all the program memory was in use, so I stopped everything, but that did not make a difference. There was still no memory left. I had to reboot the PPC to get the program memory back. When I reopened the Note only, the issue repeated itself. This time I could play back the voice recording, but shutting down Note again did not release the memory. I am going to try it again from scratch (entirely new Note with voice recording(s)) so that I can verify a repro procedure, but that should be enough to give you an idea.