Quick googling around indicates that JFS, or XFS don't have these limitation.
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Many computer programs used by system administrators in UNIX operating systems often designate files with inode numbers. Examples include popular disk integrity checking utilities such as the fsck or pfiles. Thus, the need naturally arises to translate inode numbers to file pathnames and vice versa. This can be accomplished using the file finding utility find with the -inum option, or the ls command with the proper option (-i on POSIX compliant platforms).

It is possible to use up a device's set of inodes. When this happens, new files cannot be created on the device, even though there may be free space available. For example, a mail server may have many small files that don't fill up the disk, but use many inodes to point to the numerous files.

Filesystems (such as JFS, or XFS) escape this limitation with extents and/or dynamic inode allocation, which can 'grow' the filesystem and/or increase the number of inodes.
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Joseph

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