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It is ROM. It's the "left over" portion of the ROM to which Dell has given us access. You can put things there and they will survive a hard reset. I put my backup files there so that if the Ax dies, I can rebuild it without having to connect to a PC somewhere.
ROM has a cycle life. I have heard that the Dell estimate is 100,000 writes. That's a lot of writes, so I wouldn't sweat it too much, but I would generally not want to put files in the ROM that change a lot. My average PPC "life" is about 2 years, let's say 750 days. That gives me about 133 writes per day. I suppose a busy person could get that many writes if you put something really volatile there, say the IE cache or Avantgo files.
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