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RF signals could still interfere with a TV's internal circuitry even if it does use an infrared remote (which pretty much all modern sets do). Anyone who's ever used a cell phone close to a TV, regular phone, amplified speakers, etc. should know this. Having your hand near the TV could serve as a sort of antenna for stray RF signals, or it could be reflecting a stray IR signal (remote stuck under a couch cushion with the power button jammed down, perhaps?).
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