Some phones don't support SD cards over 32GB, because of the filesystem https://en.wikipedia.org/wiki/Secure_Digital#SDIO.2C_SDHC_and_SDXC … but how come some are limited to 64/200GB?
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Windows won't *let* you make a >32GB FAT32 partition, but that's not the same thing. I think I ended up using a third-party tool
The Sansa Clip+ predates SDXC cards entirely I think, so figuring all of this out was a bit of an adventure