Yeah I'm lost at this point - perhaps Lyle knows what is going on here. I don't have experience with UPS module myself, just USPS - but I thought the data that gets sent via POST would be one long string? Is that data you are sending... is that how it's formatted in the $request? Because normally when an http request goes out as POST it's usually just one long string full of url-encoded variables. Is that not what UPS requires?

And if it is what UPS requires, which I'm sure it is, the question is: why isn't your server formatting it correctly?