I receive the same problem:
Copying a few thousand files from a Samba-share (Ubuntu 9.10, Samba 3.4.0) to 
Windows 7-Client (Ultimate x64) produces the error message mentioned above 
after a few seconds. It's a Windows Dialog. The exact Message is:
"Too many Files are currently in use. Quit one or more programs, and then try 
again."
I can choose between [Try again], [Skip] and [Cancel]

Waiting a few seconds and then choosing [Try again] copies a few more
files until the message reappears. the longer I wait the longer it
copies without interruption.

Executing the command metioned above results in
"fs.file-max = 196754"
That's 10 times bigger than the total amount of files to be copied.

One thing I noticed:
"sudo smbstatus"
shows only two open files while idling but about 1013 open files in the moment 
when the message appears. While the dialog is open, the list shrinks 
continuously. After a few seconds it's nearly empty again.

I didn't notice the problem on Ubuntu 9.04 using Windows XP Professional
32-Bit as client.

A simple manual copy using the Windows GUI is basically possible, but
other tools consuming a big amount of shared files seem to be unable to
handle the exception properly (e.g. 7-zip crashes completely).

It seems that Samba doesn't close opened files fast enough. I cannot
decide whether Windows forgets to close the files properly or Samba
ignores the close event.

An (obfuscated) example line of an opened file in smbstatus:
"1920         1000       DENY_WRITE 0x20089     RDONLY     EXCLUSIVE+BATCH  
/home/me   My Files/my file.txt   Wed Nov  4 21:42:44 2009"

It's a big problem for me since I'm totally unable to work with projects 
persisting of 1000+ files.
The problem can be permanently reproduced in my case (1 GB/s LAN). Network load 
is around 1 % except for some 20 % peaks. The test project consists of many 
small text files (source code).

If there's any more information I can provide to solve this problem,
please let me know.

Kind regards

Kai

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samba "Too many files are currently in use."
https://bugs.launchpad.net/bugs/462172
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