I have an app which let users to pick an image from sd card and then app process the image. I am downsizing images to 1/5 of avialable vm memory and i do call recycle() for every bitmap in onDestroy() call and i still get out of memory error if i close and open my app multiple times.
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There are various memory leak scenarios in Android. One way to track them down is to use the Traceview tool http://developer.android.com/guide/developing/debugging/debugging-tracing.html.
For more info on common Android memory leak problems see http://android-developers.blogspot.co.uk/2009/01/avoiding-memory-leaks.html