I believe with the R1 versions of Hyper-V this was more true, but with Windows Server 2008 R2 Hyper-V and Systems Center Virtual Machine Manager 2008 R2, there are features that remove this obstacle. First of all, with Live Migration in Hyper-V, I can now migrate my VMs from one machine to another as workloads change. This can by dynamic with the PRO Tips within VMM 2008 R2. This means that I can run my machines to higher utilizations and get the most out of the boxes. We don’t have memory overcommit, like ESX Server, but for most customers, we can still run a tremendous amount of VMs. ::
Memory overcommit is mentioned in passing, but its a rather important distinction. Check out this blog:
http://blogs.sepago.de/helge/2008/09/25/vmware-vs-microsoft-why-memory-overcommitment-is-useful-in-production-and-why-microsoft-denies-it/
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