I run in to this problem as well, from time to time. It's never really bothered me that much, but I see that it happens when I open a few pages that have a flash animation in them. I'll open one flash page, close it, open another one, close it, open a third one, crash. I end up using xkill to close mozilla/firefox, and then just restarting X altogether. I'm thinking it's just a problem with flashplayer.
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