There have been a number of threads in zones-discuss relating to Solaris 10 patching. Most of the feedback came from folks who ran into issues related to delayed activation patching, or patching zones that run on ZFS file system. Running zones on ZFS file systems is not currently supported by Sun, but it appears installing the latest version of 119254 or 119255 will help address a number of issues related to running zones on ZFS file systems. I am posting this here for future reference, and in an effort to help others who may be stumbling into issues applying patches to their Solaris 10 hosts.