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I've used WME9 to encode WMV at 20fps and it plays just fine on my PPC2002 Axim. If the new WMP on WM2003 (don't ya just love all these abbreviations? :p ) is so much better, it may be able to handle a higher framerate as well.
With DivX and PocketMVP, I can get 30fps in portrait mode without the Axim even breaking a sweat, and 24-25fps seems to be the maximum for fullscreen landscape mode.
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