Given the huge number of laptops, pda's, phones and other such items--including ones with state secrets--that are left in taxis each day, it would be best to always completely power down if you aren't actually using the machine.
All in all, taking any reasonable precautions, such an attack is very unlikely.
Luckily it is also fairly easy to prevent in most circumstances.
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Encrypted disks
wizodd, for example I never turned off my laptop usually keep it stand-by or hibernated, however all value information I use is located on virtual encrypted disk (PGP disk), so if even my laptop is stolen the thief will find its desktop locked and in case if thief gonna copy my value files from HDD he should take out the HDD from laptop to connect it to other PC, after he shutdown the laptop the encrypted disk is not accessible anymore. The password length is 15 chars, so it is not easy to hack the virtual disk image :-)