Without any context, your question doesn't make any sense. If you are running a 32 bit application, the amount of opened sheets might push you to the limits of available memory ram.
you will run out of windows handles (an operating system limit) if you open too many windows. Old operating systems had much lower number of available handles.
I am assumng that you are talking about an MDI app
That's not a question that I have really thought about, I think the user would loose the plot on the number of Sheets opened long before any windows restriction was hit.
Do you have a particular concirn or a "real world" problem that you need help with?
Regards
David
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What I mean with "limits" is RAM memory limits.