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https://issues.apache.org/struts/browse/STR-2959?page=com.atlassian.jira.plugin.system.issuetabpanels:comment-tabpanel#action_41251
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Niall Pemberton commented on STR-2959:
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Hmmm had forgotten this was an interface :( but I suspect in practice most 
people use the default CommonsFormFile implementation and wouldn't be affected. 
IMO theres no real difference breaking compatibility either by changing the 
method signature or adding a method for anyone implementing the FormFile 
interface. Whatever the solution though the issue still remains about breaking 
compatibility between versions.

At one point (2-3 years ago!) Martin was talking about enhancements to Commons 
FileUpload then would make the struts file upload features redundant - 
unfortunatley he moved on to pastures new without it coming to fruition. 
Anyway, from memory, there are a number of deficiencies in the file upload 
implementation (?multiple files with the same name, content encoding, and 
perhaps/probably more?) - each of which probably require at least breaking 
compatibility if not a new clean implementation. My question is - are we going 
to just address this deficiency or are others going to come along/be fixed in 
dribs and drabs? I would hate to see us repeatedly having this conversation. 
The best approach would be to review all the outstanding issues and consider 
them all togteher - but that sounds like a much bigger job and would need 
someone interested in working on it.

> File upload has 2GB limit
> -------------------------
>
>                 Key: STR-2959
>                 URL: https://issues.apache.org/struts/browse/STR-2959
>             Project: Struts 1
>          Issue Type: Bug
>          Components: Core
>    Affects Versions: 1.2.7, 1.2.8, 1.2.9, 1.3.5
>         Environment: Websphere Application Server 6.0 
>            Reporter: Richard Harding
>            Priority: Minor
>             Fix For: 1.4.0
>
>
> Struts currently has a 2GB limit on file upload.  
> org.apache.struts.upload has an artificial limit of 2GB.
> org.apache.commons.fileupload does not have this limit since 'long' is used 
> in place of 'int'  

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