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|System Administration Guide: Oracle Solaris Containers-Resource Management and Oracle Solaris Zones|
The zonepath of a non-global zone should not reside on ZFS for these releases. This action might result in patching problems and possibly prevent the system from being upgraded to a later Solaris 10 update release.
Note that the root file system of a non-global zone can reside on ZFS starting with the Solaris 10 10/08 release. Solaris Live Upgrade can then be used to upgrade the system.