Bizarre question I know, but I figured if anyone could answer it, Mumnetters could...
We have 2 sets of Dr Brown bottles, bought at different times so not just one faulty bottle. Both seem to leak when we're heating the formula in water... standing upright! 
So bottles are on side in fridge, not leaking and then we take them out, put them upright in warm water and then they leak. We're using the lid thing below the teat. They have hardly any formula in them so it's not that they're overflowing. We lost 40ml out of 120ml just now, so it's not a small amount.
Are we doing something silly to cause this?