I also found this article.
I was just reading your column, and I noticed the question from the guy (Bigdg, I think it was) about why Windows gives out of memory errors when he tries to defrag. Your answers were good, but I would bet $50 that I know why it is happening...
Up until about a month ago, I did technical support for Windows 98. As drives got bigger and bigger, we discovered something interesting - Windows will always give not enough memory errors when you have one huge partition (i.e. bigger than 13GB or so, ...) and you defrag it. The reason is the way Windows breaks down the partition into clusters. The FAT32 file system was not really designed to handle the number of clusters you get when you have a partition that big, so no matter how much RAM you have, it will always crap out on you...
The solution I would recommend would be to repartition into smaller partitions, preferably under 8.1GB. You lose the advantage of FAT32 when you have a partition bigger than this, because you go from 4k clusters (good - the reason you want FAT32 in the first place) to 8k clusters (the same as FAT16, and with a partition that damn big, you're going to see a performance hit because of it... This should take care of the out of memory errors that Bigdg and others in his predicament are having...
So my guess is that its pushing the limit right now.