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Journalistic research (or any kind of web based research).

Sure there are better ways to do it, but for less tech savy users a combination of browser windows and tabs are a good way to keep track of "thought branches". I do it sometimes, I google a topic (and open tabs) then when an interesting branch comes up I spawn a new browser window and then repeat the process again.

Why should lots of open tabs cause a problem? Worse case a browser should just unload them and pull them back from the cache when they are activated.

I upvoted you to get you back to even. I think this is a very vaild question. There is no reason to downvote this; and I am interested myself to the reasoning...

I agree, I didn't even think you could open that many tabs. I don't know how anyone expects a browser to run optimally with that many resources open.

I thing chaosmachine was right when he said it is partly because of increasingly dynamic web content.

When pages were (mostly) static you could have 100 tabs on a slow machine and it wouldn't matter because they were mostly in the swap file. The more pages try and become active without a mechanism for the browser to "pause" them the bigger the problem lots of tabs becomes.