That's the number I have cursed, now that you mention it. I saw a system one time on a service call where the person used folders like they were a frickin' note page - there were all these little essays disguised as folder names when you opened Explorer. I asked why she did this since it you couldn't put a file or a sub-folder in them, (255 limit).
Her reply was it didn't matter, it was handy for her....
People use computers in ALL kinds of ways, I've found. Though, it did stick with me and I now make 'notes' in directories, particularly in folders where I download software to when testing applications. I just make a new 'text' file and use the filename for the 'quick look' note for things like "no forum" or "30 days free", etc, etc... it is handy