Nokia N-Gage... "In Memorial"
The problem with active cooling in phones is not the size or even the power consumption of cooling fans, but the intake of cool and exhaust of warm air. Specifically, you don't want to blow hot air on the user's hand and you also want to keep the intake clear of any obstructions. Active cooling with poor air circulation is useless and might actually be worse than well-designed passive cooling. Furthermore, the air vents will kill any water resistance and circulating air will introduce dust to the insides, which is potentially a bigger problem in phone format than in a laptop or hybrid tablet.
In order to pit active cooling (like the surface) means losing waterproofing and little bit battery
So it's one or another
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