I don't really get the whole OE thing. What benefits would there be to switching to OE?
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In the past, when most OZ users were using OPIE rather than GPE and everything was based around 2.4 kernels, there was a big difference between OZ and pdaXrom. Now, that everyone is moving to a 2.6 kernel and EABI, there isn't so much of a difference anymore. OE is the builder tool to build OZ/Angstrom similar to the pdaXrom builder. The advantages of the pdaXrom builder was that it could spit out a X86 as well as a ARM version of pdaXrom. The X86 version could be booted off a CDROM or used from inside VMWare or other virtual machines. In addition, pdaXrom builder also build a ready to use native zgcc image for the Zaurus. These and the fact that pdaXrom was still based around 2.4 kernel which was although slower than the 2.6 kernel, much more stable and supported all the Zaurus' (clamshell models) hardware, and glibc 2.2 which made it easy to port to Sharp/Cacko, ie pdaXqtrom.
Now, there isn't much of a differentiator anymore. Everything is aiming at using 2.6 kernel, the use of EABI means that the latest glibc and gcc will be used. The only difference will be the packaging and even in that, both distros are becoming more and more similar in that regard. One difference that remains is the ipk format, but that isn't a big issue.
CJK was one of the reason pdaXrom was more popular for some people, but it isn't really supported well in the latest of either distros. Application wise, OZ/Angstrom tends to only provide optimised applications that run quickly and use little resources, whereas pdaXrom enphazised on supporting almost any opensource linux application that users wanted to use on their Zaurus.
So to answer the question, the difference would be much smaller these days, but the effort to convert everything to using OE would be quite considered and what gain would that provide? It isn't like pdaXrom doesn't have a build tool yet or its current tool doesn't do the job properly, so there isn't really a point in moving to OE.