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1-29-2013, using AutoCAD 2012... and I'm experiencing this issue on 'some' drawings. Again, no UCS is present... it just doesn't make any sense.
Well - in case anyone else runs across this... I found the answer here: http://forums.autodesk.com/t5/Visual-Basic-Customization/ActiveX-SetPlotWindow/td-p/321369
In short, SetWindowToPlot expects the values in DCS (Display Coordinate System). DCS is not always equal to WCS - so you have to translate the points from WCS to DCS. I am still a bit puzzled by the fact that 95% of the time (if not more) DCS == WCS.