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It was a huge pain for me. Was considering going to an Apple store to get it fixed. I did the full "recalibration" technique, and I haven't had issues since then.

Granted, this is anecdotal. But at least for me, it did the trick. I have a iPhone 4 iOS 4.2.6, if that helps.

My 4g ipod touch has this problem; regretfully, my warranty expired before I could do anything about it.

... recalibration does nothing for me.