Sun Cluster cannot yet cluster LDOMs as a HA resource of its' own.   Therefore 
you can't failover LDOMs from one physical server to a second physical server.  
 VCS has that capability.   

Given that, for example, you have to shutdown all of your guest domains when 
you upgrade LDM software, the ability to failover your LDOMs to a different 
host would be a very valuable feature.
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