The simplest answer is that you may not be allowed a win2k3 server or management doesn't want WSUS.

I work for a gov't agency and it would take the net admins 3 years of testing before they would attempt it... We still haven't upgraded all the desktops to XP yet... and there are still a few NT servers floating out there.

I'm sure it is great and all, but it isn't all things to all people
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