IIRC when we migrated if you have a maximum message size it also refuses to 
move those, we had to disable those during the move window - I think the issue 
was that it uses SMTP as the transport.

From: Michael B. Smith [mailto:mich...@smithcons.com]
Sent: 06 June 2012 15:52
To: MS-Exchange Admin Issues
Subject: RE: Migrating big mailboxes from 2003 to 2010

No, not really. Be aware that 2010 has a default maximum mailbox size of 2 GB, 
so you will need to adjust that before starting your moves.

Sent from my Windows Phone
________________________________
From: Al Rose
Sent: 6/6/2012 10:25 AM
To: MS-Exchange Admin Issues
Subject: Migrating big mailboxes from 2003 to 2010
Hi,

Are there any restrictions on mailboxes size in regard to migration scenario? 
We are planning to migrate from Exchange 2003 to 2010 and we have users with 
10Gb mailboxes.

Thanks

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