The code <CFFILE ACTION="" is misleading: the action is not actually an upload, but just moving the file from the location the HTTP server has stored it, to the location specified in the CFFILE tag.
The upload is not triggered by the CFFILE tag, but by the form action and method.
CFFILE will just handle the file once it has been uploaded.
Now, where does the HTTP server stores the file temporarily, is another question.
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