In ArcGIS 10 SP 2 I get an intermittent error when using IMap.SelectByShape(). The error is "Exception from HRESULT: 0x80041599." This occurs when I am doing feature selection. I click an area on the map and it throws the error. I bypass the error and click again and I don't see the error. It does not seem to be related to a particular map or location on a map. I see some old errors that threw this particular error code but nothing I can connect with this behavior.