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Depends how much power and noise you're willing for it to make!!

Remember that texas instruments DLP technology which is in use in pretty much every office/home cinema projector is effectively micro flip-dots micromachined in silicon, and that can operate at ~10,000 FPS.

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With my rudimentary physics knowledge I'd think that smaller structures can be moved faster than bigger structures.

EDIT: also when you google a bit you can find a guy who maxed out flip dot displays at 30fps (which honestly I thought would not be possible either)

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Uhm yeah they are a lot smaller. That makes a difference obviously.
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