I can't believe how much I lean on the Note 5's S Pen. I don't even take my S3 out of the briefcase at case management conferences anymore. The Phone is perfect in that role when taking down deadlines for drafting the conference order and other management issues. The phone is unobstrusive, is readily available in my jacket pocket, is instant-on and, most importantly, the pen is in the silo where it belongs In fact, the tablet pen only gets used for annotating cases and marking-up or signing documets. I couldn't justify another device just for note-taking.