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Some monitoring systems don't carry out tests until the car has gone through a number of cycles - starting, etc. - after you clear the codes and lights. Then after the right number of cycles, the system starts testing again and the CEL will pop back on if the problem wasn't fixed. It's not clear - at least to me - what these cycles actually are, but that's why it seems so arbitrary when the CEL comes back on. Good luck in finding the root cause of the problem.
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