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I was clarifying that it was file size and not partition limitiation.
I use a 1TB, as FAT32 in my Dev Kit... However, windows built in formatter wont format anything over 32 or 64gb as FAT32 (I forget and can't be arsed googling) -
I use(d) http://xrl.us/bgrgqv to format my 1TB as FAT32, but again, if you want large file support, you'll need HFS+