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The only significant factor in determining if you can update MonTel 16bit to 32bit is to make sure you have the correct minimum version of the Master Client Database.
You can check this by having a look at the MonTel System Info form found on the Help menu of the MonTel tool bar, and looking for the Value "Master ClientDB version:". The value needs to be at least 1.54 to be able to update directly.
If the Master ClientDB version is less that 1.54 and greater than 1.25, refer to the topic How to update 16bit databases older than 1.54 for details on how to download a special update program (UPDATE16.EXE) that will update the database to version 1.59.
This means that you can update any version of MonTel 16bit to the 32bit version as long at the Master Client Database version is greater than 1.25. This will cover the vast majority of sites.