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2 comments of this product found across Reddit:

dmorrissettejr /r/GalaxyNote20

1 point

1970-01-19 11:52:55.537 +0000 UTC

I ordered this and phone lays flat.

https://www.amazon.com/dp/B089CPVHJX/ref=cm_sw_r_cp_apa_i_UUYpFbHV8ZRTP

Solidant3 /r/GalaxyNote20

1 point

1970-01-19 12:13:13.268 +0000 UTC

I have this case and it makes the phone flat on the camera side:
https://www.amazon.com/Spigen-Tough-Designed-Samsung-Galaxy/dp/B089CPVHJX/ref=sr_1_2?dchild=1&keywords=spigen+tough+note+20+ultra&qid=1599193237&sr=8-2