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Recommended solution for High Availability on traditional File Services shares in a Hyper-V Failover Cluster

Introduction: When establishing HA for Print Services in 2012, it is no longer possible to Cluster Print Services on the service-level, but instead we now have to cluster on the VM level through VM Monitoring. How about File Services running in VMs that expose tradional/Non-SOFS shares like redirected folders, user drives and Roaming profiles (in my case in combination with DFS namespaces). If we cluster on the service-level, we can still restart/shutdown/update one of the Windows Systems that holds the File Service at a time, but then we would have one extra Windows Server VM/system running/taxing the Host.

Question: Is it recommended to establish High Availability for virtual machines running File Services for generel use by clustering on the VM-level or on the service-level?
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Cliff Galiher
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Thank you. That was a very good answer!