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I’ve been thinking about this further:

_Surely the argument about DataReaders isn't the cost of opening the connection, it's the fact that the connection lives much longer and hence reduces scalability?_ > >

One could make the argument that in fact getting a connection, getting you data, and getting off as quickly as possible, is much more important than the efficiency of DataSet’s or otherwise at the middle tier. It’s generally a lot easier to scale out the middle tier than improve the scalability of the database.