More Consumer Reports sensationalism:

Any reasonably competent, well-intentioned writer or editor would assume that most people reading this would think the new iPad gets hot, implying severe discomfort and a significant flaw that will affect nearly everyone who uses it, rather than merely warm, which would imply an occasional minor inconvenience for the few people who might notice and care.

Clearly, no such editor is employed by Consumer Reports.

Source: Marco.org