Maximum Number of Open Windows under Windows?

Triones asks: "I have found that Windows 2000 has a limit on the number of distinct windows that can be opened. W2K cannot open more than around 70 distinct windows (duplicate IE's on the same url don't count) even when it has 50Mb free phyiscal memory and much more in system cache. The max I can get is about 75 windows. Similar limits on machines with 256Mb or 512Mb ram. Some of my friends have reproduced this phenomenon on their systems. (By the way, no such problem with Linux (Redhat, XFree86, Gnome, Sawfish)). Is it related to the graphics 'resource' (GDI?) in Windows? Is there a parameter that can be tuned to increase the limit? If this is a 'flaw', is it fixed in XP?"