I've had both, but I prefer heated. I think it depends on the type of establishment. Also, whether it is being prepared fresh for you. Pre-packaged (or pre-slic

I've had both, but I prefer heated. I think it depends on the type of establishment. Also, whether it is being prepared fresh for you. Pre-packaged (or pre-sliced, but not universal) tends to be cold while fresh tends to be warm. Then there's toasted which obviously comes out hot. I guess it could also depend on the definition of cold sandwich, which could be different region to region.