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Black absorbs and radiates heat faster than white. In the sun, black things get hot quickly. Theres also the fact that it isn't an accurate temp reading, and sould be taken with a grain of salt.
while that is true, black loses heat/energy much quicker than white colours. As such a black ds would only get hotter under endothermic conditions, or where the surrounding area is hotter than the device. if the surrounding area is usually cooler than the 'ds' itself.
well there is a way to check if the temperature sensor is in the battery, charging the battery will heat it up. there should be a change in temperature in the sensor if the ds is being charged.