It really doesnt matter, just make sure that you dont move it when a disk is running, and the 360 has plenty of breathing room and isnt in a closed enviroment like a tv stand or something similiar.
i personally have my xbox 360 lying down because i know its safter because if tis stood up it runs the risk of falling while a disc is in there you never know just keep the 360 well ventilated and you will be ok
I would go with lying it down. It doesnt matter if your careful, but there is much less risk of it falling of the cd moving inside when it is lying down thanks to gravity. If you wanna be safe go lying down
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