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When you create a virtual machine on a GSX Server host either by deploying a template or by cloning another virtual machine, VirtualCenter checks the availability of file system space for the maximum size configured for the virtual disk. VirtualCenter does not check the virtual disk file's current size. The operation fails if there is not enough space.
To resolve this issue, make sure the destination host has the virtual machine configured for maximum disk space. The allocated or non-allocated configuration of the GSX Server virtual machine does not impact this issue.