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Another tough question to which the only answer I can give is: That depends!
You see, in terms of raw file serving there is mixed feedback about comparative efficiency. Some sites have claimed that Samba is faster, others that there is not much difference on the same hardware. No recent benchmarks are available to prove this one way or the other.
So far as file system intrinsics are concerned, NetWare has a file system that is far richer in terms of file attributes stored than a Unix file system. Samba is limited by the intrinsic capabilities of the native file system it sits on top of.
One area where Samba pays a very high price is in the handling of 8.3 file names. Samba implements a method of file name mangling to dynamically create 8.3 file names. Additionally, Unix/Linux file systems are case preserving and case sensitive -- under a Unix environment Samba has to implement case insentive file name handling itself. This is user-space CPU intensive. NetWare is built for this type of file name handling, does this in kernel space, and thus with lower overhead.
So in real world benchmarks I would expect (on the same hardware) that in raw file serving Samba may outperform NetWare, but on filename resolution NetWare would run rings around Samba.
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