question about NAS VAAI "Full File Clone"

Per http://www.vmware.com/files/pdf/techpaper/VMware-vSphere-Storage-API-Array-Integration.pdf I understand that the Full File Clone primitive is only used if the VM is powered off, in contrast with the XCOPY primitive on block storage, which is invoked when the VM is powered on.  My question is, is this a limitation of VMware, or of the NFS protocol?

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