Description:
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Hello,
thought i submitted this before but obviously not

PHP scripts are intermittently returning CGI Error - did not return a full set of headers

This was also a problem with perl and Microsoft pointed it out to be the following problem. The following solved the same error in Perl and from what I understand headers are nothing to do what the coder adds to their php scripts but what php.exe puts in. Anyway here is what they say im hoping its what the problem is (please read IIS6's rules that are enforced) Even though these rules are enforced they only cause intermittent issues with scripts

Basically IIS6 enforces additional rules that previous IIS versions didnt

For your CGI, it needs:
print "Status: 200 OK\r\n"

There are a couple of CGI rules being enforced on IIS6:
1. Per CGI 1.1, a response must contain the "Content-Type" header,
optionally the "Location" header, and also indicate the Status code via
either the "Status" header or something like "HTTP/1.1 200 OK\r\n". This is
a big gotcha for people.
2. Headers must be terminated with \r\n per HTTP 1.1 spec.

#2 has some peculiarities in that depending on the CRT's IO Mode -- in Text
mode, "\r" will be inserted for you for every "\n", while in Binary mode, no
such thing is done. This means that since you need to be certain that
"\r\n" terminates every header for IIS -- either you run in binary mode and
send the "\r\n" yourself, or you run in text mode and only send "\n". 

Reproduce code:
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any code

Expected result:
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it will load all the time

Actual result:
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intermittent cgi errors - not returning full set of headers