SnapManager for Exchange, that application with the worlds 3rd worst GUI (only beaten by SMMOSS and SMSQL) can, in common with every other VSS aware Exchange 2010 backup product can protect the passive copy of an Exchange 2010 database. However, and here's the thing; you have to be careful on your timings.
If you deploy SME to protect the active copy once a day in case you need to do an active restore and also do longer term protection on the passive you will want to pay very careful attention to the contents of your snapinfo directories.
If you take a backup of the passive the transaction logs will be purged from the active (since a backup happened) but a snapinfo structure will ONLY be created on the passive. So if you're on the active and want to do a partial restore to a particular point in time for whatever reason you may not be able to go all the way up to that point because, although you have all the logs SME thinks you should, SME doesn't have every one of them.
Obviously there is no point at which an active restore without data loss cannot be done. You will know where the latest backup is and can always restore up to date. It is only those partial restores for (say) forensic examination or single mailbox recoveries that might be affected.
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So in this case it would seem that the best practice would be to only do your database backups from the primary. This isn't really any different than how SME works currently since other versions of Exchange don't work the way 2010 does. I suspect a new release of SME geared just at Exchange 2010 will probably pop up sometime this year.
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