I'm wondering if there was some fundamental limitation that caused this restriction? Here's the thing -- Because it can't be used from a UDF, it hinders it's usefulness:

Example: you make a package of UDFs (call it Pack), with a UDS initializer (call it Init). Init uses ptrGlobalDefine to set up a shared array or something. Works great, I've tried it, all udfs in Pack see the array. Big step forward for WinBatch, IMHO.

But what if you want to call and use Pack from another UDF (call it Fred)? That won't work, because Init won't be getting called from the main program. Boom.

Easy enough to fix I guess, by moving the Init call out of Fred into the main program. But the main program should not have to assist in internal details of Fred. It should simply pass in parameters and consume results.