I can't find any documentation that says create might fail for this reason,
One likely cause is tag-along programs such as virus checkers, content indexers, backup agents etc. They like to open files immediately after an application has written to one and then closed the file. And while they hold it open you can't delete it.
If you use Subversion on Windows you sometimes encounter this. Subversion creates and renames a lot of files. They even have an FAQ entry about this: http://subversion.tigris.org/faq.html#windows-access-denied You can read more in the bug it references: http://svn.haxx.se/dev/archive-2003-10/0136.shtml The only solution is for apps that see access denied on Windows when they shouldn't to loop a few times to see if the situation resolves itself. Roger