Palms, Pda's can go up to 128-160.

Phones in the line of 6600 - Ngage - e398 - Set it at 35-80 (exception of e398 on latest firms - you can encode it upto 200)

k750i, W800i, 6630, 7710 - Same as palms and Pda's.

Now since company's keep upgrading their firms - especially in the case of Moto and SE - The performance of Bitrate keeps getting better (e398 at first couldn't handle 80, on latest it can go upto 200, see the diff ? )

All i can say is encode - if it lags - reincode in smaller bitrate.