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The problem is not available RAM, but available driver memory. The kernel only allocates so much memory to the device drivers and if that memory gets "eaten" up, then you get an error like this. Unfortunately, I don't know if it really is the Bluetooth driver's fault as it occurs on devices from multiple manufacturers that probably use different Bluetooth drivers. It may be that the OS is leaking driver memory, just like it leaks main RAM. That could be why the OEMs can't issue a patch to fix it.
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